Chemical Process Safety (PSM/RMP)

West, TX Fertilizer… a lesson in “process safety” and the “retail facility” exemption?

Before the dust settles and the funerals are complete, the politicians and the media are already clamoring for more regulations in order to prevent another catastrophe like the one in West, TX.  However, like in many occasions, it is not the regulatory framework that is the problem; it is the “retail” exemption and its improper […]

Hydrogen Fluoride Study, Report to Congress Section 112(n)(6) Clean Air Act As Amended

Under section 112(n)(6) of the Clean Air Act of 1990, as amended, Congress required EPA to carry out a study of hydrofluoric acid (also called hydrogen fluoride (HF)), to identify potential hazards to public health and the environment considering a range of events including worst-case accidental releases, and to make recommendations for reducing the hazards,

OSHA’s “hydrocarbon fuel exemption” in PSM

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

Facility Siting 101 – Vehicle Barriers around critical equipment (NH3 Tank Damage from Semi – Photos/Layout/RMP)

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

The CSB and API appear to be at odds on Recommended Practice ANSI/RPI 755, Fatigue Risk Management Systems for Personnel in the Refining and Petrochemical Industries, First Edition, April 2010

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

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