On August 28, 1992, a cryogenic tank ruptured in Hokkaido, Japan, and is a textbook case study in the catastrophic consequences of completely isolating a cryogenic vessel. The explosion occurred in the middle of the night at a food processing factory. The blast destroyed the upper half of the facility, damaged 25 surrounding buildings, and […]
The transfer of hazardous materials from a cargo-tank motor vehicle to fixed-site storage poses a critical vulnerability in chemical handling. While high-speed highway collisions capture more attention, the Pipeline and Hazardous Materials Safety Administration (PHMSA) estimates that roughly 25% to 50% of serious HAZMAT transportation incidents actually occur during loading and unloading operations. These accidents
When we introduce a pipe welding machine (such as an orbital welder) into the fabrication process, the focus of the certification fundamentally shifts. Under industry codes such as ASME Section IX, the individual operating the equipment is no longer classified as a “Welder”; they are designated as a “Welding Operator.” Because the machine handles the
I am working with a client who is making every effort to comply with the Maximum Allowable Quantity (MAQ) limits for a flammable liquid process area. This process is a PSM-covered process, so I offered up how to work beyond the MAQ of 480 gallons for a fire control area. This compliance option 5001.3 was
One state and two territories no longer implement the program, and the Regional office has taken over implementation for those three (3) areas. One (1) county in KY and three (3) counties in NC have been delegated enforcement authority. FL, ND, and MO have a partial delegation for either LPG or NH3. The current list
I grew up in the process industries doing PSM/RMP; however, most of the air receivers at my plants were NOT associated with the PSM/RMP-covered process(es). And yet they were all in our MI program for routine inspections and testing of their PSVs. In fact, every pressure vessel in service on the plant site and its
NOTE: If you’re in an INDUSTRIAL facility, especially one with a PSM/RMP-covered process, B31.9 is NOT your piping RAGAGEP! IFC 5703.6.3 dictates that piping for flammable and combustible liquids must be hydrostatically tested to 150% of the maximum anticipated pressure (or pneumatically tested to 110%). However, it offers a carve-out: “Unless tested in accordance with
I will be fully upfront for those who wish to challenge me on this topic. YES, ASME B31.3 and 31.5 explicitly state that certain records that are required by the standard do NOT have to be “retained”. However, most people who challenge me on this topic fail to see that ittybitty two-letter word “if” in
Structural collapse caused the release of around 2,400kg of highly flammable liquid petroleum gas.HSE investigation found that long-standing corrosion of the steel tower was not dealt with.Workers exposed to the risk of serious injury and burns in a major incident. The refinery has been fined £1 million after a major gas leak following an investigation
The Chain of Failure The catastrophe centered on the unloading area for liquefied petroleum gas (LPG) tanker trucks and unfolded over a matter of minutes. Botched Connection: Around 1:00 a.m., a driver attempted to connect an omnidirectional loading arm to the tanker’s discharge outlet. The connection procedure was complex, and the driver failed to secure
OSHA uses the General Duty Clause (GDC), Section 5(a)(1) of the OSH Act as a “gap filler” to cite employers for recognized chemical hazards when a specific standard (like the Process Safety Management standard, 29 CFR 1910.119) does not technically apply. There are some critical legal limitations on GDC Enforcement: OSHA’s ability to invoke 5(a)(1)
As I said in my previous posts on GDC PSM citations, this is new territory for me and OSHA enforcement. I was always taught (and by some very sr. OSHA personnel) that OSHA can not use the GDC to enforce hazards for which OSHA already has a standard for. It was OSHA’s “carrot and stick”
