Chemical Process Safety (PSM/RMP)

EPA RMP & EPCRA citations @ amino acid manufacturing facilities (NH3, Cl2, 37% HCL & $458K w/ $224K SEP)

SPECIAL NOTE: the Cl2 was generated by a truck unloading incident that was a WRONG CHEMICAL-WRONG TANK event (phosphoric acid to sodium hypochlorite) which produced 973 pounds of Cl2. Respondent owns and operates two amino acid manufacturing facilities located near each other (the Facilities). One Facility specializes in food and beverage industries (Foods), and the…...

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EPA RMP & EPCRA citations @ amino acid manufacturing facilities (NH3, Cl2, 37% HCL & $458K w/ $224K SEP) Read More »

NH3 leak during refrigeration condenser replacement

Up to 100 pounds of ammonia was released outside a public athletic club with indoor ice facilities. The leak happened during decommissioning work of an ammonia refrigeration condenser by a refrigeration contractor and resulted in the facility enacting their Ammonia Release Emergency Protocol. Multiple workers and members of the public were in the area at…...

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Protecting the PSM/RMP covered process (IFC 5001.3.3.6)

Those who follow my posts closely know I am a massive fan of bollards for physically protecting hazardous materials processes. These simple and inexpensive posts have saved my butt over my career more times than I can count, and yet so many still are unaware of their need and requirements. But these bollards are for…...

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Hot Work on flammable and combustible liquid storage tanks

In light of the recent HSE video showing a 30′ silo exploding and going airborne for 9 seconds, I thought it might be fitting to offer some guidance on how to SAFELY perform HW on these “used containers.” OSHA’s 1910.252 standard provides no advice other than to say that we must be “absolutely certain” that…...

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IFC and Hot Work Signage

As you know, I am a big fan of the International Fire Code and utilize it more than outdated OSHA standards. One requirement the IFC has that OSHA does not is that “conspicuous signs shall be posted to warn others before they enter the hot work area.” Such signs shall display the following warning:… Membership...

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Hot Work on “used containers”, including process vessels, results in two workers receiving life altering injuries

On 20 September 2017, two employees of were using a grinder to cut and replace pipework at the top of an 11-metre (40’) high metal tank containing waste slurry. They were not using harnesses. Sparks from the grinder ignited flammable gasses causing the tank to explode. The slurry vessel was airborne for 9 seconds and…...

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Hazards of Pneumatic Pressure Testing/Leak Testing (Fatality)

On March 20, 2024, at noon, an employee, 34, was pneumatically leak-testing a newly installed 56-inch drainpipe. The pipe extended from one side of the street to the other, roughly 150 feet. They placed a rubber pressure plug on one side and another on the testing site across the street. At about 30 minutes into…...

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CSB updates H2S Line Break Double Fatality – Contractor(s) Opened WRONG flange

Today, the U.S. Chemical Safety and Hazard Investigation Board (CSB) released an update on the agency’s investigation of a fatal release of toxic hydrogen sulfide gas at the PEMEX Deer Park Refinery in Texas on October 10, 2024, which killed two workers and injured 13 others. PLEASE UNDERSTAND we may know WHAT happened, but we…...

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A look inside the Caramel Processing area

Last week, we saw the devastation of a catastrophic failure of a pressure vessel (PV) in Louisville, KY. We still do not know the cause of this failure, just that it was a “cook vessel #6. SAFTENG members can see my breakdown of the photographic evidence available from the Courrier Journal (local Louisville newspaper). But…...

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Line Break/Equipment Opening GONE BAD (185F water)

Another example shows us that serious hazards can be found OUTSIDE of chemical processes, and applying the Line Break/Equipment Opening Procedure and Permit to these hazards could go a long way in controlling these recognized hazards. DEFINING and QUANTIFYING “hazardous energy” sources is STEP 1 in ensuring the process/system can be safely opened. Step 2…...

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