Vulnerable zones are areas that could be affected by a release from a chemical accident at a facility subject to the risk management program requirements in 40 CFR Part 68. How can one determine if they live or work within a vulnerable zone?… Membership Required You must be a member to access this content.View Membership...
RMP “Vulnerable Zone” Determination Read More »
As part of the hazard assessment, owners and operators of Program 2 and Program 3 covered processes must identify and analyze alternative release scenarios (40 CFR §68.28). What criteria should be used when selecting an alternative release scenario?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in...
UPDATE on Criteria for selecting alternative release scenarios (4/2023) Read More »
Many organizations use blinding/blanking as their main means for isolating a Permit-Required Confined Space. But a number of years ago, an unqualified operator mistook a “Paddle Spacer” for a “Paddle Blind,” thus leaving the flammable gas pipe to the PRCS improperly isolated. There is a very distinct way to tell these two in-line devices apart…...
Reading blinds and blanks identifiers (ASME B16.48) Read More »
One of my favorite topics to discuss during hazard analyses, incident investigations involving LOPC, and audits are the use of torque wrenches. These wrenches play a critical role in process safety, yet they may be among the top 5 abused and misused tools in the mechanic’s toolbox. And sadly, many still wish to argue that…...
Not a trick question; however, I bet it made you stop and think for a second. There are many stories/scenarios involving LOPC events where a pressure gauge was not maintained or not read properly. This year we got involved in an LOPC event and testing done on the critical pressure gauge showed it was way…...
Does reuse of a pressure gauge in a different service or location need an MOC? Read More »
I took this photo as part of an investigation to assist a potential new client in their defense against an OSHA citation. This setup is exactly what OSHA took issue with. A DOT container “dropped” and was being used as a “storage tank” since its motive power had been removed. This practice caused the PSM…...
Transportation Containers and PSM/RMP Read More »
The folks “up north” are miles ahead of OSHA and EPA process safety standards in one simple but HUGE difference… Process Safety Leadership for Senior Management. This standard, not fully embraced by all provinces within Canada, is something that OSHA and EPA should consider adopting in their efforts to revise their compliance standards. This 2022…...
The role of Senior Management in Process Safety Read More »
CSA Z767 stipulates that human factors must be considered in risk identification and quantification. In doing so, the design of operator process/equipment interfaces with written guidelines and procedures, staffing levels, and the working environment (noise, vibration, lighting, temperature) should all be considered from the perspective of their effect on both the levels of protection (line…...
Canada got it right with their Process Safety standard (CSA Z767:17) – Human Factors Read More »
First, let’s DEFINE what we mean when we use the term “remotely operated shutoff valve.” I have come to love the UK’s HSE definition, which is: A valve DESIGNED, INSTALLED, and MAINTAINED for the primary purpose of achieving rapid isolation of plant items containing hazardous materials in the event of a failure of the primary…...
Whenever we are dealing with piping and vessels that use nuts and bolts as their joining method, there was always this “rule of thumb” about “short-threading” and “3-threads showing.” But now these “rules of thumb” may be no more, based on ASME PCC-1–2019, 8.2 Bolt Lengths. I was raised/trained in this as a fundamental in…...
Is “short-threading” and “3-threads showing” a thing of the past? Read More »
A pipe with 100 psi liquified Chlorine started to leak at the point where the pipe is connected to the plant construction. The pipe was high in a pipe bridge without easy access for inspection, which was done 6 months prior. The inspection missed this critical point. …...
Pipe hanger causes Chlorine LOPC event Read More »
There is a new source for RMP Data. This new source is provided by the Data Liberation Project. Below is a breakdown of the new site – data was last updated in 2022…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
New EPA RMP Database Read More »
