Chemical Process Safety (PSM/RMP)

Two (2) NH3 nurse tanks catastrophically fail in 3 months

This past week, we saw the 2nd catastrophic failure of an NH3 nurse tank in three months.  This is indeed a rare occurrence.  Both incidents appear (from news accounts and photos) to be circumferential weld failures on these vessels.  Both vessels failed while they contained NH3 (levels unknown), but neither was actively being filled at…...

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The results are in… 1/4 turn valves need that little sliding lockout tab

One of the most common valves used in industrial settings is the 1/4-turn ball valve.  From 1/4″ up to 6″, these valves are everywhere, regardless of the risks they may pose.  Recently a client and I discussed these valves and their risk in highly hazardous chemical processing.  I have had several incidents over my career…...

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Line Break gone bad (Fatal ClO₂)

On June 27, 2022, an employee at a packaging plant was flushing a chlorine dioxide pump for maintenance when some of the chlorine dioxide escaped the process and he inhaled it. The employee was rushed to the hospital and later died…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member?...

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Cascading Failures vs Failing Safely

In the world of Human Factors, we have a saying, “failing safely,” which translates into… all humans make mistakes – it’s our job to identify those error/mistake traps and design work to lessen those error opportunities.  In Process Safety we used to use the phrase “cascading failures”, which is the opposite of “failing safely.”  In…...

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Chemical Facility Anti-Terrorism Standards (CFATS) program EXPIRES

As of July 28, 2023, Congress has allowed the statutory authority for the Chemical Facility Anti-Terrorism Standards (CFATS) program (6 CFR Part 27) to expire. Therefore, CISA cannot enforce compliance with the CFATS regulations at this time. Due to this lapse in statutory authority, CISA cannot enforce compliance with the CFATS regulations. Access to the…...

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Is a PSSR “necessary” for a Replacement in Kind (RIK)?

Notice I used the word “necessary” and not the word required.  In my experience, a PSSR saved my ass plenty of times when OSHA/EPA did NOT require it.  To my knowledge, OSHA (nor EPA) have defined the word “facilities” in the context they used it in 1910.119(i)(1)… (emphasis by me) 1910.119(i)(1) The employer shall perform…...

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HVAC Contractor’s Scissor Lift causes NH3 release & fatality

At 11:09 a.m. on December 19, 2022, an HVAC contractor was installing a heating unit when a coworker operating a scissor lift struck a NH3 pipe/valve that caused a release of ammonia. The contractor, 68, was overcome by ammonia and died.  The lift operator was hospitalized for treatment for his exposure to ammonia…. Membership Required...

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Natural Gas Excess Flow Valves on Residental Feeds

Today I saw our local Natural Gas service provider discussing installing an Excess Flow Valve with my neighbor.  So naturally, that caught my ear, so I mossed over to learn more.  It seems that most Natural Gas service providers are offering the installation of an Excess Flow Valve on the feed to homes.  Of course,…...

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Attention to detail needed with Respiratory Protection and Cl2 exposure

At 11:00 a.m. on May 23, 2019, an employee removed a regulator from a chlorine gas cylinder to perform yearly maintenance and repacking. When the employee attempted the close the shutoff valve, the valve malfunctioned and stopped turning while still slightly open without the employee’s knowledge. When the employee removed the regulator, chlorine gas escaped…....

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Line Break gone bad (pyrophoric materials)

Two workers were injured on an offshore platform while installing a skillet, the steel circular joining plate inside a section of piping. The incident occurred while the workers were on scaffolding and unbolting a 10-inch flange (Figure 1). After determining the skillet was the wrong size, the supervisor instructed a third worker to join the…...

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Lack of Maintenance to Uninterruptible Power Supply Systems Leads to Failures (BSEE Alert)

Uninterruptible Power Supply (UPS) is a pretty common backup power supply in industrial settings where “power failure” can lead to the loss of control systems, emergencyshutdown systems, and emergency mitigation systems.  But like ALL SAFEGUARDS we take credit for in our Hazard Analyzes, these UPS must be in our mechanical integrity program for testing/validation regularly…...

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Is a public road considered a public receptor?

A process covered under 40 CFR Part 68 is eligible for Program 1 requirements if it meets all of the criteria listed at 40 CFR §68.10(b). One of those criteria is that the distance to a toxic or flammable endpoint for a worst-case release assessment is less than the distance to any public receptor. Are…...

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