I will be fully upfront for those who wish to challenge me on this topic. YES, ASME B31.3 and 31.5 explicitly state that certain records that are required by the standard do NOT have to be “retained”. However, most people who challenge me on this topic fail to see that ittybitty two-letter word “if” in…...
Structural collapse caused the release of around 2,400kg of highly flammable liquid petroleum gas.HSE investigation found that long-standing corrosion of the steel tower was not dealt with.Workers exposed to the risk of serious injury and burns in a major incident. The refinery has been fined £1 million after a major gas leak following an investigation…...
The Chain of Failure The catastrophe centered on the unloading area for liquefied petroleum gas (LPG) tanker trucks and unfolded over a matter of minutes. Botched Connection: Around 1:00 a.m., a driver attempted to connect an omnidirectional loading arm to the tanker’s discharge outlet. The connection procedure was complex, and the driver failed to secure…...
OSHA uses the General Duty Clause (GDC), Section 5(a)(1) of the OSH Act as a “gap filler” to cite employers for recognized chemical hazards when a specific standard (like the Process Safety Management standard, 29 CFR 1910.119) does not technically apply. There are some critical legal limitations on GDC Enforcement: OSHA’s ability to invoke 5(a)(1)…...
As I said in my previous posts on GDC PSM citations, this is new territory for me and OSHA enforcement. I was always taught (and by some very sr. OSHA personnel) that OSHA can not use the GDC to enforce hazards for which OSHA already has a standard for. It was OSHA’s “carrot and stick”…...
Apparently, they can and have. Here are some GDC citations for an NH3 refrigeration process. These were part of a large release inspection that included some HAZWOPER and HAZCOM citations. My only guess is that these GDC citations are tied directly to the NH3 release, but I have not yet seen the field notes, so…...
A Hierarchy of Controls Analysis (HCA) is a highly structured risk-mitigation methodology. It is specifically required under CalARP Program 4, which applies to petroleum refineries operating within California. While a standard Process Hazard Analysis (PHA) identifies risks and lists existing safeguards, an HCA forces a facility to systematically evaluate whether hazards can be eliminated or…...
A Safer Technologies and Alternatives Analysis (STAA) is a systematic risk management evaluation used in process safety engineering to identify and assess ways to make a process inherently safer. Instead of relying solely on add-on safety equipment or administrative procedures to manage a hazard, an STAA asks: Can we eliminate or significantly reduce the hazard…...
When flammable liquid tanks are equalized — meaning they are interconnected by piping that allows fluid levels to equalize between them — we MUST account for this in our secondary containment design. From a regulatory and engineering standpoint, the governing principle is to protect against the worst-case single-event release. If tanks are interconnected, a failure…...
Now that we have laid out the code requirements for conducting the visual inspection of pipe welds, let’s discuss how this must be documented…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
ASME Section V, Article 9 places the responsibility for the designation and qualification of these individuals on the organization (the employer or manufacturer). The organization is responsible for assigning “qualified personnel” to perform visual examinations. ASME Section V requires that personnel be qualified and certified in accordance with a program established by their employer. The…...
The next layer of the onion to unpack is the specific requirements for performing “Visual Examinations”. This is all part of the installer’s Quality Assurance program. We are getting deep into the weeds as we “peel this onion”, but these are CRITICAL needs to ensure our pipe is erected properly per the ASME B31 code(s)…....
