No hunman and no organization is perfect! Although we should strive for perfection in all aspects of business (Production, Quality, Cost Control, and EHS), we often mis-step or possible loose our way altogether. But how bad do things have to get before it is a REAL PROBLEM?
I continue to see facilities struggle with the emergency shutdown SOP requirements and how it is all suppose to flow and fit into the daily operations. In this post I will try and lay out a flow to help make sense of these PSM/RMP requirements. I am hopeful you can learn from my mistakes, as
We do not see these types of failures often, but when we do, it can almost always be traced back to human error. Back in 2008, a tube-and-shell heat exchanger catastrophically failed when workers accidentally closed two different valves at two different times between the vessel and its relief valve. On June 10, 2008, operators
Does the title make you scratch your head? I usually get some strange looks when working with a client who is trying to understand what the PSM compliance cycle looks like. To start with, let’s look at what OSHA/EPA requires in our operating procedures: 1910.119(f)(1)(ii) Operating limits 1910.119(f)(1)(ii)(A) Consequences of deviation 1910.119(f)(1)(ii)(B) Steps required to
If your PSM/RMP covered process contains a flammable liquid, 1910.106 has provided us with some regulatory facility siting requirements that we can quickly inspect to ensure we meet the minimum compliance distances. If you have liquefied petroleum gases within your facility, 1910.110 provides some basic siting requirements that should be met to have an argument
Many chemical processes that are covered under OSHA’s PSM and EPA RMP rules utilize one of the most popular forms of passive mitigation ever known…Diking. However, on the other hand, many of the facilities have not included their dikes in their Process Safety Information (PSI) or their Mechanical Integrity Programs (MIP).
I had an interesting dissertation given to me on how to calculate “frequency” when analyzing a PHA scenario during a recent PHA. Although it sounded logical, it was completely off base and thus would have shown the facility at very low risk for all their scenarios. This is something we see from time to time
Since the great recession of 2008 -2010 we have seen an increase in the used equipment market. This is due to so many businesses going under and auctioning off their equipment and the remaining businesses needing to find ways to save $.
Fundamental safety management failings were the root cause of Britain’s most costly industrial disaster, a new publication reveals. The report into the explosion and five-day fire at the Buncefield Oil Storage Depot in December 2005 tells for the first time the full story of the Health and Safety Executive (HSE) and Environment Agency’s (EA) investigation.
Members of a key congressional panel have called for a long-term extension of the U.S. Homeland Security Department effort that sets regulations for facilities that manufacture, use, store or distribute substances that could be used to produce chemical warfare materials. While lawmakers lauded the program, they expressed frustration with aspects of the effort that have
Cites Need for Emergency Drills, Following Pressure Vessel Codes
Yes, there is a safety program called the car-seal program. In most chemical processing plants, a car-seal program is a CRITICAL program in their PSM/RMP program; however, this program has uses in almost any type of facility with relief valves, cooling water systems, eyewash/safety showers, etc. This program is designed as an administrative control technique
