Chemical Process Safety (PSM/RMP)

OSHA cites API 510, 6.2 Inspection During Installation

I first wrote about this API 510 requirement in July 2019, and now OSHA seems to have caught on to this requirement; this year, they issued their first Citation against this requirement. Of course, the citation was related to a PSM-covered process. Here is the API 510 requirement for newly installed pressure vessels and the…...

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Pressure Test gone BAD (Fire Hose #2)

Employee #1, a firefighter, was performing a pressurized hose test on a 4-inch fire hose. The employee was standing at the pump panel of the fire truck next to the discharge point where the hose was connected by a 2.5-inch double female adapter to the 3.5-inch fitting on the truck. The hose was being brought…...

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Pressure Test gone BAD (Fire Hose)

On November 3, 2006, Employee #1, a firefighter/paramedic, was the designated pump operator during the performance of an annual hose test. The pump on the fire department apparatus was utilized to perform the test. Near the conclusion of the 5-minute 400 psi test, while Employee #1 was reducing the pressure in a hose being tested,…...

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Pressure Test gone BAD (Fatality)

On September 20, 2018, an employee was performing a pressure test of a residential sewer line when he was struck in the eye by a small piece of a pneumatic quick connection of a pressure test kit…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Failed Pressure test results in broken arm

There are very good reasons why workers are required to be a “safe distance” from equipment that is being “pressure tested”. These safe distance requirements apply to BOTH pneumatic and hydrostatic pressure testing. Had these distances been honored/respected, a component failure during the pressure test may cause damage, but not an injury! On August 26,…...

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Pressure Test gone BAD

On April 21, 2020, Employees #1 and #2, 37 and 63, were conducting a pressure test on a chiller. Employees #1 and #2 were unaware there was pressure in the chiller. When they began removing the 1/2″ nuts off the bolts holding the flange in place…… Membership Required You must be a member to access...

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Elevated Line-Break goes BAD

On February 28, 2020, an employee, 36, was tasked with replacing a gasket in a 6-inch bolted flange on top of the Platformer Heater at an Oil Refinery. The employee was working in a man basket on top of the Platformer Heater. The employee loosened the bolted flange while using hand tools to remove a…...

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EPA RMP & EPCRA citations @ amino acid manufacturing facilities (NH3, Cl2, 37% HCL & $458K w/ $224K SEP)

SPECIAL NOTE: the Cl2 was generated by a truck unloading incident that was a WRONG CHEMICAL-WRONG TANK event (phosphoric acid to sodium hypochlorite) which produced 973 pounds of Cl2. Respondent owns and operates two amino acid manufacturing facilities located near each other (the Facilities). One Facility specializes in food and beverage industries (Foods), and the…...

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EPA RMP & EPCRA citations @ amino acid manufacturing facilities (NH3, Cl2, 37% HCL & $458K w/ $224K SEP) Read More »

NH3 leak during refrigeration condenser replacement

Up to 100 pounds of ammonia was released outside a public athletic club with indoor ice facilities. The leak happened during decommissioning work of an ammonia refrigeration condenser by a refrigeration contractor and resulted in the facility enacting their Ammonia Release Emergency Protocol. Multiple workers and members of the public were in the area at…...

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Protecting the PSM/RMP covered process (IFC 5001.3.3.6)

Those who follow my posts closely know I am a massive fan of bollards for physically protecting hazardous materials processes. These simple and inexpensive posts have saved my butt over my career more times than I can count, and yet so many still are unaware of their need and requirements. But these bollards are for…...

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Hot Work on flammable and combustible liquid storage tanks

In light of the recent HSE video showing a 30′ silo exploding and going airborne for 9 seconds, I thought it might be fitting to offer some guidance on how to SAFELY perform HW on these “used containers.” OSHA’s 1910.252 standard provides no advice other than to say that we must be “absolutely certain” that…...

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