Chemical Process Safety (PSM/RMP)

Outsourcing Responsibility: Explosion at Optima Belle (CSB Video)

A CSB safety video on its investigation into the fatal December 8, 2020, explosion at the Optima Belle chemical facility in Belle, West Virginia…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Disconnecting “process hoses” needs to be controlled by either an SOP or a Line Break Permit

At 12:30 p.m. on February 7, 2022, an employee, 45, was disconnecting the discharge line of a 4-inch mobile water pump. The discharge line was blocked with ice, and the running pump was deadheaded, leading to a buildup of heat and pressure in the discharge line after the check valve…. Membership Required You must be...

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Flanged Joint Assembly Records (ASME PCC-1)

As we have discussed here for years, “flanged joints” are usually MORE difficult to manage than are welded connections. However, somehow the rumor got started that flanged connections can be done by “Billy Joe Jim Bob.” Nothing could be further from the truth! And guess which connections most often leak? Yep, flanged connections. There are…...

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Large-scale (10K pound) Cl2 Release in Freeport, TX

Betting this was just under 10 pounds. That’s a RQ joke as the RQ for Cl2 is 10 pounds – CLEARLY we have exceeded that in this event. (But you never know!) All jokes aside, this is a big one. People wanting to know why it’s taking so long to get an “all clear” 2-hrs…...

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Learning Human Factor mistakes from others

The PSM standard requires the employer’s PHA team to evaluate human factors during its process hazard analysis. CCPS defines human factors as “a common term given to the widely-recognized discipline of addressing interactions in the work environment between people, a facility, and its management systems.” The basic principle of assessing human factors is to determine…...

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Learning MOC mistakes from others

The Management of Change (MOC) section of the PSM standard requires the employer to implement written procedures for managing changes (except for replacements in kind) to processes involving chemicals, technology, equipment, procedures, and changes to facilities that affect a covered process. The MOC procedure requires descriptions of the technical basis for the change, impact on…...

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Learning MI mistakes from others

OSHA has identified the following mistakes found at PSM facilities nationwide. These mistakes were identified at refineries; however, almost all can be found within any PSM-covered process. I have revised OSHA’s wording so that we can ALL learn from these mistakes. PLEASE do not fall for the old trap of “Bryan, we are not a…...

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When to Revise OCA (EPA RMP FAQ)

The risk management program in 40 CFR Part 68 requires facilities to conduct an off-site consequence analysis (OCA) to provide information to state, local, and federal governments and the public about the potential consequences of an accidental chemical release. When does a facility need to revise its OCA?… Membership Required You must be a member...

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Quantity of a regulated substance in an aqueous solution (EPA RMP FAQ)

When using RMP*Comp to conduct an offsite consequence analysis (OCA), a facility must specify the quantity released. What quantity should be entered for a regulated toxic substance in an aqueous solution, the total quantity of the aqueous solution or just the quantity of the toxic substance?… Membership Required You must be a member to access...

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No trespassing signs restricted access onsite or offsite public receptor (EPA RMP FAQ)

The definition of public receptor is “offsite residences, institutions (e.g., schools, hospitals), industrial, commercial, and office buildings, parks, or recreational areas inhabited or occupied by the public at any time without restriction by the stationary source …” Offsite is further defined to include “areas within the property boundary [of the stationary source] to which the…...

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Must I anticipate a specific cause for the worst-case scenario for a toxic substance? (EPA RMP FAQ)

When analyzing the worst-case scenario for regulated toxic substances, must I anticipate a specific cause (e.g., fire, explosion, etc.) of the scenario?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Identifying public receptors and property with restricted access (EPA RMP FAQ)

Does public receptor cover only buildings on a property or the entire property? If the owner of the land next to my site restricts access to the land, is it still a public receptor?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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