Chemical Process Safety (PSM/RMP)

Human Error leads to Cl2 exposoures during truck loading

At 4:00 p.m. on May 10, 2021, an employee working for a chemical supplier was transferring chlorine-containing product from a storage tank into a tanker truck. A valve intended to direct the displaced contaminated air to be scrubbed of chlorine was accidentally left CLOSED. The chlorine-containing air was then not scrubbed and was allowed to…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

Line Break Gone Bad (Cl2)

This event is a perfect example of why all piping openings are hazardous. At approximately 7:00 p.m. on November 15, 2006, Employee #1 was a process operator at the Chlorine Liquefaction Unit, Block A-19. He was preparing to bleed off chlorine on a process line to clear the line for maintenance work. The valve handle…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

OSHA issues Facility Siting citation under 5(a)(1) rather than PSM

NOTE: these are from the fatal 2014 NH3 Truck Unloading accident, where the “bleed tank” (which was a plastic IBC) catastrophically failed because a liquid NH3 valve was left open. I have no idea why this 5(a)(1) was not issued as a RAGAGEP citation using ANSI K61/CGA 2.1, which is where the facility siting requirements…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

Shop Pressure Testing piping with Nitrogen leads to asphyxiation

At 8:04 a.m. on May 11, 2023, an employee, 58, working for an oil and gas support services company, was found dead. On 5/10/23, the night before, the employee had instructed his coworkers from other contractors to go home, and he would finish the job up. This was the last time anyone had spoken to…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

Equipment Opening Gone Bad (Railcar Manway)

At 8:00 a.m. on January 19, 2021, two (2) employees (42 and 52) were preparing to take a sample. As they were loosening the manway bolts, an explosion occurred. The employees were hospitalized for burns to the hands, arms, and lower back, as well as a fractured left femur. Awaiting Citations… Membership Required You must...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

Your Human Factors, Process Safety Tip of the Week

Ensure your “units of measure” are CONSISTENT If the sight-glass for LEVEL is in Inches = the SOP needs to state INCHESIf the TEMPERATURE Gauge/Panel reading is in Degrees C = the SOP needs to be in Degrees CIf the PRESSURE Gauge/Panel reading is in PSIG = the SOP needs to be in PSIG… Membership...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

Pressure Test gone bad (Steam Vessel failed during pressure testing)

Six (6) workers were injured when an air tank exploded at an industrial filter production plant. Two (2) of the workers received treatment at a local hospital with major injuries to their faces and heads. According to authorities, an air tank that was being tested exploded at 11:14 a.m. at the industrial filter manufacturing plant…....

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

Inspections vs Audits (Part II)

Last year, I shared Part I regarding the difference between the two words: Audit and Inspection. Today, I want to explain how and why OSHA/EPA “inspect” and we “audit” our PSM/RMP-covered processes. To put it bluntly, an OSHA/EPA “inspection” does NOT and will NEVER replace our 3-year PSM/RMP audits. Both EPA and OSHA require RMP/PSM-covered…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

Chemical Accident Risk Reduction NECI Goal FY 2024 RESULTS (NH3 and HF)

Launched in 2017, this Chemical Accident Risk Reduction National Enforcement and Compliance Initiative (NECI) seeks to reduce risks to human health and the environment by decreasing the likelihood of chemical accidents. This will be achieved by addressing significant noncompliance with the general duty to maintain a safe environment and risk management plan rules. Given the…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

What does an RMP $10M SEP look like?

The SEP will provide the emergency response equipment to the identified emergency response organizations to assist them in responding to emergencies in the communities where the Covered Refineries operate and where chemical processes are undertaken that the CAA regulates. XXXXX is obligated to expend Ten Million Dollars ($10,000,000), which includes all administrative costs associated with…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

What constitutes “significant property damage on site?”

Under the hazard assessment requirements at 40 CFR Part 68, Subpart B, the owner or operator of a covered stationary source must document a five-year accident history that includes all accidental releases from covered processes that resulted in deaths, injuries, or significant property damage on site, or known offsite deaths injuries, evacuations, sheltering in place,…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

Are chemicals in a tank car exempt from threshold determinations under 40 CFR Part 68 (RMP)?

Back to an old question that continues to be asked… Are chemicals in a tank car exempt from threshold determinations under 40 CFR Part 68 (RMP)? The definition of stationary source does not apply to transportation, including storage incident to transportation (40 CFR Section 68.3).  Are chemicals in a tank car (e.g., tanker truck or…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here
Scroll to Top