Over the years we have seen a very large movement to skinny down PSM/RMP operating procedures. At first glance this movement makes a lot of sense; but with any great idea comes pitfalls and it is the pitfalls that I would like to discuss in this posting. Recently we came across the end results of…...
This material has been provided by the Nevada Division of Environmental Protection Chemical Accident Prevention Program. This is an EXCELENT SOURCE of reliable information regarding PSM/RMP procedural needs, but it is provided by a STATE AGENCY and may not meet/exceed federal agency expectations. I find it very hard to think that Federal OSHA or EPA would not…...
During a PSM/RMP audit this week with my “Partner in Safety”, Unwin Company, Mr. Bob Johnson shared this GREAT worksheet and explanations from the Nevada Division of Environmental Protection Chemical Accident Prevention Program. The purpose of this extensive data form is to assist facilities with the compilation, organization and evaluation of the information that is required to…...
If you’re involved in process safety you know about mechanical integrity and what is mandated by OSHA’s PSM and EPA’s RMP in regards to MI. But many businesses are just scratching the surface with their mechanical integrity program(s). This article is meant to help those who are looking to take their MI program(s) to the…...
In 2011 EPA inspected a national company that distributes ammonia and found several concerns that were eventually addressed in a settlement agreement. One of the business’s facilities is about a tenth of a mile from a residential neighborhood, and even closer to other public businesses. The way the facility was operating, according to EPA, if an ammonia…...
In order to protect the public from boiler and pressure vessel explosions, guidelines must be in place to ensure proper construction, installation, inspection, operation, maintenance, alterations, and repairs. However, these guidelines do little to protect the public unless they are mandated by law. In order to encourage the development of essential safety laws in jurisdictions that…...
A tradesman was nearly sprayed with heavy fuel oil while attempting to change the suction strainer on a pump. He was removing the securing bolts from the strainer when the incident occurred. Initial findings indicated that the suction and discharge valves were not isolated and the system contained a tank header pressure of 80-100Kpa at a temperature…...
There is one PSM/RMP task that continues to cause problems and is still heatedly debated within process safety circles. In all of the PSM/RMP requirements from OSHA and EPA standards, Line Break/Process Opening is the one area where there is no Recognized and Generally Accepted Good Engineering (RAGAGEP) for how the task is to be…...
In the past few decades many things have changed in the world of Hazardous Materials and many of these changes DIRECTLY IMPACT our process safety efforts and our PSM/RMP compliance. The debate will continue as to where DOT stops and OSHA begins when it comes to compliance coverage regarding loading and unloading Hazardous Materials, but…...
Steaming railcars and tanker trucks is a very common practice in many industries; however, the hazards of doing so it not widely known nor understood. Much like we cover “TOO MUCH TEMP” in our process hazards analysis, a similar analysis may be called for to analyze the practice of applying a heat source (e.g. steam…...
Earlier this year I wrote about the risks in using “truck drivers” as your HAZMAT Attendant, as well as using the carrier’s hose for your loading/unloading activities. I have also posted several “Safety advisiories” from state and federal agencies regarding the mis-use of transfer hoses. Many of you appreciated my bluntness and brining the concerns…...
Earlier this year I wrote about the EPA Safety Alert regarding having high expectations of an Excess Flow Valve being a reliable safeguard to stop an uncontrolled flow of a HHC/EHS. This article is another example of how these valves should NOT be considered a safeguard and most certainly should NOT be the sole layer…...
