Chemical Process Safety (PSM/RMP)

ASME 1949, CGA 2.1, and NH3

It not often I come across a 70+ year old PV still in pristine condition. Below is the name plate for this vessel and it carries an interesting code compliance story. As I said, it’s not often to find a NH3 storage vessel this old and because of its age, it carries some SPECIAL PRV…...

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Temporary SOP, Car Seals or BOTH?

What would you require for this bypass around a safety critical valve? Temporary SOP, Car Seals or BOTH? The automated valve is the Emergency Shutoff Valve tied to a Hi-Hi Interlock on an above-ground atmospheric flammable liquid storage tank. The LOPC/Over-Fill event occurred because the worker filling the tank was “shorthanded” that day and had…...

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“Pouring Conduit” in my HAZLOCs (Video)

What exactly does this phrase mean, and how is it done? This is a CRITICAL aspect for conduit in our Hazardous Locations (HAZLOC). It is something we should be checking (sampling) in our conduit runs in our HAZLOCs. The video below is by far the best I have ever seen that explains why we “pour…...

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“Gas Detection” requirements coming to the OH Fire Code (2024 Edition)

The state of OH is currently working on its next revision of the State Fire Code. As in the past, the basis for these revisions comes from the International Fire Code (IFC). One major revision for those in the state of OH will be Section 916 – Gas Detection. This is an EXCELLENT RAGAGEP for…...

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British Columbia: Adoption of Boiler, Pressure Vessel, and Refrigeration Codes

Big changes in the Province of British Columbia for boilers, pressure vessels, and NH3 refrigeration processes. The Province has published Ministerial Order M225-2024 that provides amendments to the Power Engineers, Boiler, Pressure Vessel and Refrigeration Safety Regulation (PEBPVRSR). These amendments will update the Schedule to the PEBPVRSR by adopting the new editions of the codes…....

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IN-OSHA cites chemical manufacturer for SDS issues

The day has arrived! IN-OSHA, a state-plan agency, has issued a citation to a chemical manufacturer regarding its Safety Data Sheet (SDS) for Ammonium Hydroxide (NH₄OH). OSHA took issue because the SDS did not provide the LEL/UEL range for this chemical. Now I could argue that NH₄OH is NOT a flammable liquid, and therefore, this…...

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Could it be? IN-OSHS issues a PSM citation

This is the first and only PSM citation that I have seen from IN-OSHA. It is a single violation cited for contractor safety, and it appears it may have been related to an incident involving a contractor working on an Ammonium hydroxide tank. I am NOT certain about this, just trying to read between the…...

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Sharing MI Inspection Results – Same/Similar Service

A client has a new tank farm, and six (6) storage tanks are in identical service, and three (3) others are in similar service. So the question I get often is… Since these tanks are identical in their design AND service, can we use inspection data from one (1) tank to assess the conditions of…...

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Your process safety tip of the week… (API 570)

When classifying your piping circuits for MI/TML/CML inspections, DON’T share the inspection/NDE frequencies with the team!!! It is amazing to watch them “reconsider” their decisions after they learn the differences in inspection frequencies between Class 1 and Class 2. The exercise is to ENSURE the integrity of our PRIMARY CONTAINMENT (process safety); not to reduce…...

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Line Break Gone Bad (Flammable)

SAFTENG NOTE: The fatal H2S event in Deer Park last year that claimed two (2) contractor lives was the result of contractors opening the WRONG flange! Now we have a similar event that led to a fire that burned for three (3) days. A report regarding a 2025 Refinery Fire in CA found that two…...

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New RAGAGEP for Food Processing facilities using Cryogenic Food Freezing and Chilling Equipment

The Compressed Gas Association (CGA) has published P-95, Guideline for the Safe Installation and Use of Cryogenic Food Freezing and Chilling Equipment. This publication covers the installation and operation of food freezing and chilling equipment and associated supply systems, and the use of that equipment with refrigerated liquefied gases (nitrogen and carbon dioxide)…. Membership Required...

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