There are several codes and standards that call for hydrostatic relief valves to be installed in all segments of pipe that can be isolated. For example, the following two OSHA standards state the following… 1910.111(b)(9)(ix) A hydrostatic relief valve shall be installed between each pair of valves in the liquid ammonia piping or hose where…...
OSHA’s PSM exemption of “Hydrocarbons used solely for workplace consumption as a fuel” is commonly misunderstood and often improperly applied. In this article I hope to better explain how this exception can be utilized SAFELY and in FULL COMPLIANCE so that both “process safety” and “OSHA compliance” can be fully met. Let’s start by looking…...
A storage tank containing anhydrous ammonia started to leak after it was struck by a tractor-trailer about 6:20 a.m. Monday a few miles west of West Liberty-Salem schools. A semi-truck hauling floral products attempting to turn around at the anhydrous ammonia distribution site struck a large-capacity anhydrous ammonia storage tank, puncturing a supply line and…...
This is a very common question when auditing “older plants”, say plants built prior to 1960 (not a specific date with any meaning). For example, during an audit it is discovered that a vessel was built to a RAGAGEP that no one had even heard of or maybe there is NO documentation as to what…...
In March, 2007, the CSB recommended that the American Petroleum Institute1(API) and the United Steelworkers International Union2 (USW) jointly lead the development of an ANSI consensus standard with guidelines for fatigue prevention. The recommendation arose from the investigation of the BP Texas City refinery incident in 2005 (CLICK HERE for additional information on that accident). Their…...
Have you ever heard someone at your facility say, “that part of the process is not covered”? As a process safety professional, this may be our hardest battle in the big scheme of complying with OSHA’s Process Safety Management (PSM) standard and EPA’s Risk Management Plan (RMP) rules. In this article I would like to…...
Fire-resistant garments are provided to the select few who voluntarily risk life and limb and go into harm’s way. They do it to ensure the safety and security of the rest of us. In this group are members of the all-volunteer military and first responders, from firefighters to the riot control units and SWAT team…...
Standard Number: 1910.132; 1910.132(a) December 18, 2012 MEMORANDUM FOR: REGIONAL ADMINISTRATORS & REGIONAL SOLICITORS FROM: RICHARD E. FAIRFAX, Deputy Assistant Secretary & JOSEPH M. WOODWARD, Associate Solicitor for Occupational Safety and Health SUBJECT: Guidance on Handling Cases Developed Pursuant to the FRC Enforcement Policy Memorandum This is to provide guidance on application of the Enforcement Policy for Flame-Resistant Clothing…...
Federal officials have charged a Georgia transportation company in a 2009 ammonia leak that killed a South Carolina woman. According to court documents, a federal grand jury returned an indictment against the transportation company for alleged violations of the Clean Air Act. The wrong type of hose was used as 7,000 pounds of anyhydrous ammonia…...
When using an MSDS to comply with the Process Safety Information requirement 1910.119(d)(1)(ii) Permissible exposure limits, is it ACCURATE to use the 8-hr TWA Permissible Exposure Limit (PEL) when the workers work 12-hour shifts? My article last week has stirred a lot of emotions from those who do a lot of “referencing” in their SOPs. So I…...
Received the most interesting phone call today and there is one more business on the plante that thinks I have completely lost my mind. Their question: “If the manufacturer of a piece of equipment has a recommended maintenance plan, and we do not follow their “recommendation”; how can OSHA issue a citation against a “recommendation”?”…...
I have written about the confusion within many industries about their “electrical classification” and what the Recognized and Generally Accepted Good Engineering Practices (RAGAGEPs) allow and do NOT allow. In 2012 we even came across facilities that were using codes from an entirely different industry being applied to their facility, which utilized an entirely different…...
