Chemical Process Safety (PSM/RMP)

Tote Tank Drain Nozzles Pose Leak Hazard (BSEE Safety Alert)

    Damage to Drain Nozzles on Tote Tanks Poses Leak Hazard BSEE has become aware of multiple instances in the Gulf of Mexico region where tote tank drain nozzles have been damaged, leading to leaks and spills during lifting events. These incidents have raised significant safety concerns, and it is crucial that possible risks…...

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What, When, and Who… can you answer this for 100% of your process components

As we end 2023, we will have exceeded 30+ years of OSHA’s Process Safety Management (PSM) standard.  And yet, still today, we can walk out into a random covered process, place our hand on a process component, and the facility will struggle to provide us a “cut-sheet” for the component (i.e., what), when it was…...

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Forklift causes 1,100-pound NH3 leak in the “interstitial space”

In a food processing facility, an employee moved a pallet from an upper storage rack using a forklift when the forks were lifted too high and contacted the roofing panel near an ammonia line. The roofing panel pushed up, bending the liquid ammonia refrigeration line. A two-bolt flange connection was strained, causing an uncontrolled leak…...

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OSHA and EPA’s missing Process Safety Elements

Those in the USA have dealt with OSHA’s Process Safety Management Standard since 1992 and EPA’s Risk Management Plan since 1999.  And although these standards established a well-needed MINIMUM performance criteria, they missed the market in what we come to expect in a proper performance-oriented standard.  OUr friends to the North have been using an…...

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The Process Safety Fundamentals (PSFs)

The Process Safety Fundamentals (PSFs) are straightforward, doable best practices designed to raise awareness of process safety and spark conversations in the field. The PSFs can often be fully satisfied, but when they can’t, it’s essential to pause and hold a meaningful conversation with the team, supervisor, and support personnel to figure out a different,…...

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Hot Work Permitting Logic

Did you know there is actually some logic behind OSHA and NFPA’s Hot Work Permitting process?  This means that even before we issue a HW Permit, we have to walk through this logic.  In essence, if we can do the work WITHOUT having to perform HW; then by all means, we do the work without…...

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Reduction in workforce, the ERT, and the MOC tool

In recent months we have seen some reductions in workforce across several clients.  Some of these clients are very mature in their approach to safety management, and others are not quite there yet.  In those businesses with a mature Safety Management System (SMS), one of these facilities is NOT a PSM/RMP facility – but they…...

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Pulling blinds/blanks is a “line opening” task (Hydrofluoric Acid)

At 1:00 a.m. on January 19, 2019, Employee #1, 45 years old, employed by a plumbing company, was working at a refinery. He was removing a blind flange in preparation for installing 2-inch piping to a 2-inch line in the MHF Alkylation unit. When the flange was unbolted…… Membership Required You must be a member...

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Reflief Valves… “Upwards and Unobstructed” (Video)

 I had the pleasure of teaching another Advanced Course on Process Safety (40-hr). When discussing Relief Systems, their design, and their RAGAGEP(s), the UPWARDS and UNOBSTRUCTED piece got many questions. ALL RAGAGEPs regarding PRDs will state “UPWARDS and UNOBSTRUCTED” or similar language. Even the older OSHA standards uses the phrase “Upward and Unobstructed” in the…...

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Hazards of thickness testing on live piping

At 12:30 p.m. on January 31, 2023, Employee #1, 45, performed cathodic protection maintenance on a 4-inch natural gas pipeline. Employee #1 removed the resin coating off the external portion of the pipeline to test the hull thickness of the pipeline. While removing the coating, the pipeline exploded. Employee #1 was killed by immolation. Employee…...

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SAMPLING a LIVE process

One of the worst injury accidents of my career occurred in a PSM/RMP-covered process but involved a non-HHC/EHS.  The chemical was “hot caustic,” a byproduct from the process used in another process’s scrubber.  A sister facility had an incident in which it was discovered that the caustic was too weak. Thus in a process upset,…...

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