Chemical Process Safety (PSM/RMP)

Comparing Classes/Divisions with Zones

The US still uses the Class and Division system to classify electrical systems in hazardous locations.  However, outside the US, the Zone system is more widely used.  Manufacturers are beginning to list their equipment based on the Zone(s) it is rated for, which can cause translation confusion.  The table below may be of help…. Membership...

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OSHA announces a revised PSM standard and an Emergency Response standard is coming this year (2023)

Yesterday, OSHA announced its plans to promulgate a revised Process Safety Management (PSM) standard and a NEW Emergency Response Standard in 2023. Executive Order 12866 requires the semiannual publication of an agenda of regulations listing all the regulations the Department of Labor expects to have under active consideration for promulgation, proposal, or review during the…...

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OSHA announces a revised PSM standard and an Emergency Response standard is coming this year (2023) Read More »

Be careful what we ask for in our SOPs and SWPs

When writing SWPs/SOPs be sure how you phrase things. KNOW your audience. An elementary teacher got what she asked for when she simply asked the class to draw a clock showing the time as 10 minutes past 11. This exercise is called the Clock Drawing Test for Cognition. Usually reserved for the elderly or someone…...

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Lack of formal PSV testing procedure and formal Car-Seal program led to LNG piping BLEVE and subsequent VCE

“The Natural Gas facility lacked a formal PSV testing procedure that included a QA/QC process to ensure that PSV’s are properly returned to service after testing with isolation valves car–sealed in their correct positions. At the time of the Incident, operators were trained to assist with PSV testing by observing another more experienced operator and…...

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Lack of formal PSV testing procedure and formal Car-Seal program led to LNG piping BLEVE and subsequent VCE Read More »

Another fatal NH3 LOPC event from a refrigeration process at a food plant

Preliminary investigation indicates that two (2) HVAC contractors were in the vicinity of the ammonia leak when it was initiated. Norwood’s first responders were able to stabilize and transport one man to Good Samaritan Medical Center, and he was then further transferred to Massachusetts General Hospital for specialized treatment.  The second contractor, 68, was deceased…...

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Another fatal NH3 LOPC event from a refrigeration process at a food plant Read More »

It does NOT take a PSM/RMP threshold to make “line breaking” a hazardous tasks

I have written numerous times about how the PSM/RMP thresholds are inconsequential regarding line/vessel opening hazards.  A 1/2″ line in a water treatment process, NOT covered by PSM/RMP as it ran on 150# cylinders, poses the same risks as if the 1/2″ line was part of a covered process.  Granted, the LOPC event could release…...

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It does NOT take a PSM/RMP threshold to make “line breaking” a hazardous tasks Read More »

Fatal opening of NH3 valve (~1,345 to 1,600 lbs released)

On May 26, 2022, a crew was in the process of cutting up and disassembling two ammonia refrigeration systems (referred to as P24 and P34 in this report) at an ice distribution facility located in the Mount Paul Industrial Park located in Kamloops, British Columbia. Those present understood that ammonia had been previously removed from…...

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Heat Exchanger opening gone bad at poultry plant – 419 pounds of NH3 released with serious injuries

At 8:42 p.m. on February 19, 2022, Contractor #1 was taking apart an active heat exchanger. While doing this, 419 pounds of ammonia were released, causing upper body burns to an the contractor. Two contractors and one employee went to the hospital. The contractor was hospitalized for treatment. … Membership Required You must be a member...

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Heat Exchanger opening gone bad at poultry plant – 419 pounds of NH3 released with serious injuries Read More »

The painting contractor for your vessel and piping is a PSM/RMP contractor

I am always amazed at how far facilities will go to “exclude” contractors from their PSM/RMP contractor program.  One that is a very common exclusion is “painting contractors”.  Here is an example of how the WRONG painting contractor, provided with a bad scope of work, can cost you more than you bargained for…… Membership Required...

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What is it about bollards that is so difficult to understand

Back in my time, we could use phrases like “dumb as a post,” and people were not offended, and they clearly understood what you were trying to convey.  I often think back to that statement when I think about bollards—such a simple, effective means to protect critical assets when designed and installed PROPERLY.  Many seem…...

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OSHA’s impact statement on Clarifying Atmospheric Storage Tank Exemption

The existing PSM standard (1910.119) applies in part to processes involving a flammable liquid or gas on site in one location in a quantity of 10,000 pounds or more. However, the existing PSM standard contains an exemption for “[f]lammable liquids stored in atmospheric tanks or transferred which are kept below their normal boiling point without…...

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Summary of Potential Changes to the Existing PSM Standard

The potential changes of scope include: Clarifying the exemption for atmospheric storage tanks Expanding the scope to include Oil- and Gas-Well Drilling and Servicing Resuming Enforcement for Oil and Gas Production Facilities Expanding PSM coverage and requirements for reactivity hazards Updating and expanding the list of HHCs in Appendix A of the existing PSM standard…...

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