Chemical Process Safety (PSM/RMP)

You know businesses are cutting costs when I get this question.  But it is a good question as we have come across “reclaimed piping” being used in a lesser-degree hazard (e.g., flammable gas to flammable liquid) process.  I personally never experienced this practice in my time in industry, but it has become more popular as…...

One of the most heated debates in the process safety arena is… Do I have to have an emergency response team?  EPA has worked to answer this question by designating facilities as “responding” and “Non-responding” facilities.  Here is a nice flow chart to help…… Membership Required You must be a member to access this content.View...

One way to reduce the risk of an ammonia leak is by monitoring for leakage through the analysis of the secondary coolant (often brine) for signs of ammonia. The secondary coolant in an indirect Ammonia system must be tested no less than twice a year. Information Paper IP-BPV-2021-08-01 outlines the requirements for a secondary coolant analysis that…...

One of the most dangerous tasks that occur within the battery limits of a covered process is “opening the process.”  This is commonly called a “Line Break” but also applies to vessels.  We won’t find a definition of “Line Breaking” in the PSM Standard; instead, we turn to OSHA’s Permit-Required Confined Space Standards (1910.146 and…...

One of the biggest hurdles for an organization entering OSHA’s and EPA’s process safety standards is that some old OSHA standards are just NOT adequate based on the new level of risks.  This is most noticeable are with flammable liquid processes.  Take, for example, 1910.106, OSHA’s Flammable liquids standard.  It is “OK” for businesses that…...

The Chemical Facility Anti-Terrorism Standards (CFATS) program requires high-risk facilities to ensure security measures are in place to reduce the risk of more than 300 chemicals of interest (COI) being weaponized. High-risk facilities are assigned to one of four (4) risk-based tiers and must develop a security plan meeting the 18 Risk-Based Performance Standards (RBPS). …...

As stated in REGO’s Warning Document… Simply retesting pressure relief valves manufactured by RegO that have been in service for several years to confirm conformance with start-to-discharge and reseal ranges does NOT guarantee that the valve is suitable for continued service. Or that the valve will perform as designed at nominal pressures or in emergency…...

“Relief valves should be inspected each time the container is filled but no less than once a year. If there is any doubt about the condition of the relief valve, it must be replaced.” Major Factors to determine the “Life” of Relief Valves include: Water/Ice Accumulation Corrosion Dirt – Debris Damage Normal Aging Eye protection…...

At 3:10 p.m. on February 2, 2022, an employee, 26, was performing maintenance on a System Applicator. The employee began the ammonia bleeding procedure wearing safety glasses and rubber gloves. After approximately 20 to 30 minutes, the employee no longer heard a whistling sound and believed that the system was completely bled out. When the…...