If you are a regular visitor to this site, you know I love to use the International Fire Code, which many states adopt in full or in some “revised” langauge as their “state fire/hazmat code”. One particular item that garners a lot of questions and comments is the IFC’s requirement that ALL hazardous materials (those…...
On May 11, 2023, @ 8:04 a.m., an employee working for an oil and gas support services company was found dead. On May 10th, the night before, the employee had instructed his coworkers from other contractors to go home, and he would finish the job. This was the last time anyone had spoken to the…...
Nitrogen (pneumatic) pressure testing fatality Read More »
This fatal incident displays the CRITICAL role of having procedures for responding to leaks, even “small releases.” 1910.119(n) Emergency planning and response The employer shall establish and implement an emergency action plan for the entire plant in accordance with the provisions of 29 CFR 1910.38. In addition, the emergency action plan shall include procedures for…...
Employee Is Killed In Ammonia Overexposure Read More »
Having spent my entire career in Flame Retardant Clothing, I learned that improper laundering could render the PPE useless, maybe even hazardous to wear. In my time, we always had a contractor launder and maintain our FRC. It was not cheap, but it was necessary to ensure the PPE worked as intended when we needed…...
FRC program – Laundering Read More »
To simplify this, the Maximum Allowable Working Pressure (MAWP) is the maximum pressure at which the hose can operate routinely. Although, I strongly suggest the “operating ranges” be far less than the MAWP. However, achieving the MAWP does NOT mean the hose will necessarily fail. Where the hose will fail is called the “Burst Pressure.” …...
Difference between a hose’s MAWP and it’s “Burst Pressure” Read More »
The criteria for determining when to retire or repair FR clothing/garments/accessories MUST provide measurable or easily identifiable damage. The following are some means to DEFINE and QUANTIFY these deficiencies:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
When does FRC fail it’s user inspection? Read More »
In 2023, I began taking issue with the condition of Flame Retardant Clothing (FRC) being used in REQUIRED areas and tasks. We see garments that in no way would pass a “routine inspection” per NFPA limitations. My go to RAGAGEP for this is NFPA 2113, Standard on Selection, Care, Use, and Maintenance of Flame-Resistant Garments…...
A Health and Safety Executive (HSE) investigation into a gasoline overfill of a carbon adsorption vapor recovery unit (VRU) revealed concerns with the design of the VRU. The overfill prevention system was NOT independent of the basic process control system (BPCS). When the BPCS failed the overfill prevention system also failed. This resulted in loss…...
OSHA’s PSM standard is over 30 years old, and EPA’s RMP standards/rule is approaching its 30th birthday fast. They are so 20th century (LOL)! This article is about how some of my clients are approaching their 3-year audits required by both standards. This approach embraces the “audit element” of the process safety management system as…...
PSM/RMP Auditing in the 21st Century Read More »
We have discussed the hazards of pneumatic pressure testing many times. Pneumatic pressure testing should be a “last resort” for pressure testing process equipment. But for those who question the degree of hazard this REQUIRED test brings about, here is something to consider. Take a look at the following comparisons between the stored energy in…...
Hazards of pneumatic pressure testing in terms of TNT energy Read More »
EPA and OSHA put out an Alert in 2007 regarding the use of Excess Flow Valves (EFV) as a “safeguard”. Although that alert has been “archived” the failures we see today align with what that alert warned us about 16 years ago! While excess flow valves (EFV) are in extensive service and have prevented numerous…...
Why Excess Flow Valves (EFV) fail to close Read More »
One of my all time favorite RAGAGEPs is the Compressed Gas Association’s (CGA) 2.1 for those who handle anhydrous ammonia. This year, they published the 7th Edition, and they made it even better. Unlike so many RAGAGEPs, the CGA embraced the practice of “Continuous improvement” and really did a nice job with their additional explanations…...
CGA updates 2.1 – REQUIREMENTS FOR THE STORAGE AND HANDLING OF ANHYDROUS AMMONIA Read More »
