How could the TX fertilizer plant be a Program 2 RMP?
I have received numerous calls and e-mails asking how this fetilizer facility with reportedly 52,000 pounds of NH3 was only a Program 2 RMP under EPA’s RMP rule. Here is the answer…
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,
Nonsparking Tools (USFA)
CLICK HERE to download the Coffee Break Training from USFA http://www.usfa.fema.gov/downloads/pdf/coffee-break/cb_fp_2013_15.pdf
Emergency Shutdown Systems and Hydrostatic Relief Valves
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 “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
What are the requirements when a component in my covered process was built to an OLD “out of circulation” RAGAGEP?
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
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
Splitting the hairs of Process Safety (Battery Limits and Changes)
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
Potential Issues When Wearing Non-Fire Resistant Base Layers with Outerwear Fire-Resistant Garments
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
Guidance on Handling Cases Developed Pursuant to the FRC Enforcement Policy Memorandum
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
Transport Company indicted in SC woman’s ammonia death (Unloading NH3)
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