Chemical Process Safety (PSM/RMP)

What is EPA’s criteria for selecting stationary sources to audit?

The implementing agency will, according to the regulations at 40 CFR §68.220(b), select stationary sources for audits based on any of the following seven (7) criteria:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Facility Siting of Pressurized Liquidfied Flammable Gas storage tanks

As we have discussed, OSHA does not have a “flammable gas” standard for those flammable gases outside the scope of its Liquefied Petroleum Gas (LPG) standard 1910.110.  So in most of my work with flammable gases, I will use 1910.110 or NFPA 58 as my RAGAGEP.  I do this as many facilities already have some…...

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We do not live in a 0.0 psi atmopshere!

I have been surprised at our profession’s lack of basic understanding regarding pressure and vacuum.  I think most people of the general public have no idea that we live under 14.7 pounds of pressure per square inch on our bodies.  We say this is what it is at SEA LEVEL, which means a lot.  As…...

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LOPC event is a classic example of the domino or swiss cheese model (CSB Report – Fatal Propylene Explosion)

The incident occurred shortly after 4:30 am on January 23, 2020, when an accidental release of propylene accumulated and exploded inside the building. The CSB found that before the incident, a hose disconnected from its fitting inside a coating booth and released propylene, a flammable hydrocarbon vapor, which accumulated inside the coating building. When employees…...

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Management of Hazardous Chemicals at Chemical Warehousing and Chemical Distribution Facilities (EPA/OSHA)

In 2021, the EPA published a Joint Safety Advisory with the Occupational Safety and Health Administration and the Department of Homeland Security Cybersecurity and Infrastructure Security Agency, focused on managing chemicals safely, securely, and in compliance with federal programs for Chemical Warehousing and Chemical Distribution Facilities. In this video, we will address the types of…...

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Ontario’s TSSA clarifies roles and responsibilities for the safe operation and maintenance of registered unattended ice surface refrigeration plants

This advisory clarifies roles and responsibilities for the safe operation and maintenance of registered unattended ice surface refrigeration plants in accordance with the Operating Engineers (OE) regulation (O. Reg. 219/01 or “the regulation) and the corresponding Director’s Order and any applicable OE Alternate Rules. Unattended refrigerated ice surfaces are an important part of Ontario’s recreational…...

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Saturday’s [process] safety sarcasm… (mechanical integrity)

As summer has arrived here in the USA, I am reminded of how fragile metal is. If blades of grass can dull our mower’s blade(s), causing cutting performance issues, imagine what heat, pressure, and chemicals can do to our piping and vessels. From design to operations to maintenance – these stages of the life cycle…...

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Failure to verify a ZES before “process opening” leads to serious incident

A natural gas processing plant is a facility designed to clean raw natural gas by separating impurities and various non-methane hydrocarbons and fluids to produce dry natural gas. Processing raw natural gas begins at the inlet gas piping or gas stream of a natural gas processing plant. This piping delivers the raw natural gas to…...

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Washington State Department of Labor & Industries (L&I) is proposing updated workplace safety rules for petroleum refineries

The Washington State Department of Labor & Industries (L&I) is proposing updated workplace safety rules for petroleum refineries designed to prevent catastrophic events like the 2010 explosion that killed seven workers at the former Tesoro refinery in Anacortes. The proposed update addresses what’s known as process safety management (PSM), which describes the way workplaces handle…...

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Concerns with the analysis of human factors in PHAs

This posting is a spin-off of information presented in the white paper from the UK’s Chartered Institute of Ergonomics and Human Factors. That paper focused on concerns with treating human factors in Bowtie’s analysis. I have modified their wording to make their valid points reflect all recognized PHA methodologies. The paper mentions eight (8) concerns…...

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CSB and Wacker determined that the fatal HCL release was due to improper TORQUING on nozzle assemble

PTFE-lined piping, such as the equipment installed in the HCl regeneration unit, requires a retorquing of flange bolts to minimize leakage from bolt relaxation. The retorquing involves bringing the processing unit to operating temperature, allowing it to cool to ambient temperatures, and retorquing to the set value. As the original equipment manufacturer (OEM) describes: A…...

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CSB and Wacker determined that the fatal HCL release was due to improper TORQUING on nozzle assemble Read More »

EPA is enforcing the amended ER Planning and Response requirements (40 C.F.R. § 68.93(a) & (c)

EPA recently issued two citations to a juice processing facility for failing to comply with the amended requirements in 40 C.F.R. § 68.93(a) & (c).  On March 21, 2022, an incident at the ammonia refrigeration facility resulted in an accidental release (the “Incident “). Pursuant to Section 114 of the CAA, 42 U.S.C. § 7414,…...

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