Chemical Process Safety (PSM/RMP)

PHA and Loss of Power

In some recent PHA’s for a client I have seen a pattern in some general assumptions that PHA teams should not be making, but often do.  It involves the “consequences” for scenarios such as “LOSS of ELECTRICTY”.  The catch is that there is a general assumption that with a “LOSS of ELECTRICTY” that everything shuts

PSM Battery Limits – it may not be as simple as “Interconnected”

OSHA’s most recent PSM Letter of Interpretation (LOI) confirms their position on covered process battery limits. I struggle with this, as their position states, and I quote, “Neither the application paragraph nor the definition of “process,” states or implies that controls can limit the extent or boundaries of a PSM-covered process.” With this position, OSHA

More OSHA PSM Citations on a NH3 Refrigeration Process (includes NO MOC on personnel changes!)

No mention if this inspection was an NEP, scheduled, or complaint; but 9 of 12 citations were PSM.  They include: 1) The employer did not develop P&IDs which accurately represent current equipment for the ammonia refrigerationsystem. 2) No periodic inspections of the energy control procedures at least annually. 3) The employer did not train affected

Explosion of MDEA Storage Tank

In August 1999, an explosion in an MDEA storage tank at a Nitrogen Products plant in Alaska propelled the tank off its base and into the air.  The tank landed on an adjacent air-cooled heat exchanger filled with synthesis gas.  The impact of the tank on air-cooled heat exchangers initiated a second explosion and fire.

Vulnerability of oil contaminated fire retardant coveralls

Coveralls become oil-contaminated very rapidly in many work situations, particularly offshore, in some cases within one day. From time to time, there are significant hydrocarbon fires offshore (eg on the Rough Platform). There is evidence that frequent washing reduces the fire retardant properties of some materials, thereby increasing personal risk to persons and compromising their

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