OSHA is considering revising its Process Safety Management (PSM) standard, 29 CFR 1910.119, to address gaps in safety coverage; or updating its Flammable Liquids standard, 29 CFR 1910.106, and Spray Finishing standard, 29 CFR 1910.107, based on the latest consensus standards. The following options are being considered:… Membership Required You must be a member to...
The first (1st) public review of draft standard IIAR 4-201x, Installation of Closed-Circuit Ammonia Mechanical Refrigerating Systems is now open. Substantive changes resulting from this public review will also be provided for comment in a future public review if necessary. IIAR 4 specifies criteria for the installation of closed-circuit ammonia refrigeration systems. It presupposes that…...
How many process safety management systems for ammonia refrigeration have you seen that included “temporary operations”? There seems to be an industry-wide mind set that there are no “temporary operations” in ammonia refrigeration. Heck, even the largest ammonia refrigeration trade group states there are is no such thing as “temporary operations” in the ammonia refrigeration…...
RMPs must be updated at least once every five (5) years. You must fully update your RMP for resubmission sooner than the five-year anniversary date, if any of the changes specified below occur [as specified in 40 CFR 68.190(b)]. If a change alters the Program Level that applies to any covered process, the RMP must…...
Anyone who has submitted an RMP or maybe done a Worst Case Scenario (WCS) using EPA’s modeling software “RMP* Comp” will recognize this little checkbox at the bottom of the data page just above the SUBMIT button… But when is this little checkbox, which can have a large impact on your scenario, allowed to be…...
We are often questioned about our audit methology and techniques. Clients ask… “How did you know to ask me about that?” or “Why in the world do you want to see that for in a PSM/RMP audit?” Well, here is one way I learned what gets asked for; attached is an official EPA RMP Inspection…...
The Bureau of Safety and Environmental Enforcement (BSEE) has released the panel investigation report into the November 16, 2012 HOTWORK explosion and fire that occurred on an offshore platform. The explosion and fire resulted in the tragic deaths of three (3) workers, serious injuries to others, and the discharge of pollutants into the Gulf of…...
Look closely… and what do you see? Think about your piping RAGAGEP(s) for pressurized piping such as ASME B31.3 or .5. Answer… What we are seeing is a piece of welded pipe that was being installed in an Ammonia Refrigeration process. As REQUIRED by ASME B31.5, Section 527.5… 527.5 Qualification Records The employer shall maintain copies…...
The Emergency Planning and Community Right-to-Know Act (EPCRA) requires businesses that store and/or manufacture, process, or use certain chemicals to complete the Tier II (EPCRA 311 and 312) Report and/or the Toxics Release Inventory (EPCRA 313) Report, also called the Form R. Section 112(r) of the Clean Air Act focuses on risk management for accident…...
A common question I receive from clients/members is “why do some of my facilities get RMP inspections from the Fed’s and others get inspected by the state; should I be prepared for both Fed and State to inspect a facility?” The answer is based 100% on where the facility is located and NO, a facility…...
This guide provides a basis for NBIC Inspectors use in reviewing Pressure Relief Devices (PRD’s) for compliance with the National Board Inspection Code (NBIC). It is only intended to provide general guidance, and must be used in conjunction with NBIC, Part 2 for specific details of inspection…. Membership Required You must be a member to...
This is one of those process safety questions: if 100 engineers were asked, you would NOT get the same answer from all 100. Although there may be other topics, this little fact would also hold true; this aspect of PSM is a critical path in process safety, so we need to get the FACTS on…...
