Chemical Process Safety (PSM/RMP)

One of the things that EPA learned from OSHA’s roll-out of their PSM standard was that not everyone recognized the standard as a 14-element management system.  So when it came time for EPA to roll out its RMP, they made a “management system” part of its requirements.  However, EPA quickly disappointed when they said all…...

At 3:00 a.m. on July 27, 2022, an employee was bolting a flow meter on a hydrogen cyanide (HCN) line that was dripping fluid with a coworker. The employee stepped away from the job after having difficulty installing the final bolts. The employee waved his hand in front of his face and backed away from…...

When your process safety consultant tells you that “torque” does not matter… after you called him/her to ask about it after you read about torque in the owner’s manual of the component you are getting ready to install… it is time to FIND A REAL PROCESS SAFETY ENGINEER. Torque values are the pinnacle of DEFINING…...

These are just two little words that cause so much debate… “at least.”  Although this is a prevalent phrase found in many Recognized and Generally Accepted Good Engineering Practices (RAGAGEP), I have found it to be one of serious debate, and it should NOT be.  First, lets see how dictionaries officially define the phrase: at…...

The registration process for RMP*eSubmit Certifying Officials recently changed to use additional CDX registration features.  The below changes went into effect on Friday, February 24, 2023. Please note that no immediate action is necessary unless one of your facilities has an upcoming anniversary date or need for a resubmission, correction or a first time submission. Identity…...

The latest NTSB Safety Alert can be applied to Process Safety! It speaks to the critical nature of “joinment” using a B-nut on fuel, oil, and air lines  on aircraft.  And it speaks to over-torquing or under-torquing as a failure mode for this joinment. A B-nut is a common term for a nut that provides…...

Senators Markey and Warren and Congressman Moulton have sent a letter to Seqens North America seeking a response to many questions regarding the business’s past accidents and compliance issues.  In the early hours of Thursday, May 4, 2023, an explosion at the Seqens pharmaceutical manufacturing facility in Newburyport injured four workers, with a fifth worker…...

The UK’s HSE has published a booklet to help manage risks when performing Hot Work (Welding, Cutting, Brazing) on “used containers”.  In the USA, OSHA has some very explicit language in their welding standards… 1910.252(a)(3)(i) Used containers. No welding, cutting, or other hot work shall be performed on used drums, barrels, tanks or other containers…...

Recently a client who uses anhydrous ammonia (NH3) had a significant event involving their NH3.  This event is the perfect scenario to demonstrate that “inherently safe design” is by far the best design.  The incident involved unloading a tank truck of NH3 into a bulk tank.  A single valve was in its CLOSED position when…...

OSHA has issued an LOI regarding 1910.119(h)(3) Contract employer responsibilities.  Here is 1910.119(h)(3) as reference: 1910.119(h)(3) Contract employer responsibilities. 1910.119(h)(3)(i) The contract employer shall assure that each contract employee is trained in the work practices necessary to safely perform his/her job. 1910.119(h)(3)(ii) The contract employer shall assure that each contract employee is instructed in the…...

Yes. At least once each calendar year, the owner or operator of a stationary source with any Program 2 or Program 3 process must conduct an exercise of the stationary source’s emergency response notification mechanisms per 40 CFR 68.90(b)(3) or 68.95(a)(1)(i), as appropriate, before December 19, 2024, and annually thereafter (40 CFR Section 68.96(a)). Additionally,…...