Chemical Process Safety (PSM/RMP)

Ohio Fire Code Requirements for Mechanical Refrigeration facilities using Ammonia

I have highlighted some surprises for those of you in OH that may be reading this!  FYI, Anhydrous Ammonia is a Group B2 refrigerant, based on Addenda to Designation and Safety Classifications of Refrigerants.  Be sure to click on the Links to the other applicable OH Fire Codes referenced in this section!… Membership Required You must...

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Simple difference between “Wet” and “Dry” Chlorine (and it matters – A LOT)

When we are reading RAGAGEPs for Chlorine Process Design, we will certainly see references to “Wet Chlorine” and “Dry Chlorine,” and it’s one of the top questions I get when people/businesses are new to the chlorine business. In the world of process safety and metallurgy, the distinction between Dry Chlorine and Wet Chlorine is one…...

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OSHA Enforcement Memo – Use of Flexible Hoses in Toxic Gas Service (10/2/2012)

After the fatal phosgene incident in WV on January 23, 2010, the CSB asked OSHA to take sustained measures to minimize the exposure of hazards to workers handling highly toxic gases from cylinders and associated regulators, gages, hoses, and appliances. Ensure that OSHA managers, compliance officers, equivalent state OSHA plan personnel, and regulated parties conform, under…...

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What is a RMP management system? (EPA)

The management system required under Subpart A of 40 CFR Part 68 is essentially a system defined by facility managers for integrating the implementation of the risk management program elements and assigning responsibility for that implementation (58 FR 54196; October 20, 1993).  The extent of the management system will depend on the size and complexity of…...

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IFC’s Performance-Based Design Alternative (PBDA)

The International Fire Code has another version of OSHA’s and EPA’s General Duty Clause. It is 5001.3 Performance-based design alternative. The code contains 18 elements that very closely mirror OSHA’s PSM and EPA’s RMP requirements, but the BIG DIFFERENCE is that the code makes no mention of quantities/thresholds! The rule applies to all hazardous materials,…...

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Process Safety and Ohio State Fire & HAZMAT Codes

Often times we get so involved with meeting OSHA and EPA regulations that it is easy to loose site of the State Fire and Hazardous Material codes.  In some states these codes can be even more stringent that OSHA and EPA process safety requirements!  PLEASE keep in mind, each state will have their OWN SET…...

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Applications and Limitations of Excess Flow Valves

EPA issued a Process Safety Alert in 2007 in response to several investigations by the National Transportation Safety Board’s (NTSB) which involved the failure of excess flow valves (EFV).   While EFVs are in extensive service and have prevented numerous pipe or hose breaks from becoming much more serious incidents, experience has shown that in some cases the…...

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Ammonia Releases in North Carolina (1993-1997 Data)

The information in this report was collected by staff in the North Carolina Hazardous Substances Emergency Events Surveillance (HSEES) Program. Ammonia releases in North Carolina have resulted in injuries, hospitalizations, and workplace evacuations. Some examples of ammonia releases in NC include:… Membership Required You must be a member to access this content.View Membership LevelsAlready a...

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Loss of Containment (LOC) Data

The UK’s Health and Safety Executive (HSE) and the onshore chemical and major hazard industries collaborated in the collection of causation information and lessons learnt from Loss of Containment incidents.  This was a voluntary scheme aimed at collecting information on the underlying causes of loss of containment events. The aim being to identify common failure…...

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PSM Emergency Preparedness (OSHA guidance)

Each employer must address actions that workers will take when there is an unwanted release of highly hazardous chemicals. Employers will need to decide: if they want workers to handle and stop small or minor incidental releases; whether they wish to mobilize the available resources at the plant and have them brought to bear on…...

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Liquefied Gas Conversion Chart

One of my many “CHEAT SHEETS” I use… LIQUEFIED GAS CONVERSION CHART Product Name Cubic Feet / Pound Pounds / Gallon Cubic Feet / Gallon Acetylene UN/NA: 1001 CAS: 514-86-2 14.70 4.90 72.03 Air UN/NA: 1002 CAS: n/a 13.30 7.29 96.96 Ammonia Anhydrous UN/NA: 1005 CAS: 7664-41-7 20.78 5.147 106.95 Argon UN/NA: 1006 CAS: 7440-37-1…...

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When we claim alarms as “safe guards” in our PHA

I have referenced these writers before when discussing process safety and once again they communicated the message better than I could regarding how we should analyze “process alarms” when we claim them to be a layer of protection.  We should only accept alarms that have been established using a RAGAGEP in their design (audible, visual,…...

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