Chemical Process Safety (PSM/RMP)

PHMSA issues guidance on NH3 Nurse Tank Non-Destructive Testing

In February 2024, the Federal Motor Carrier Safety Administration (FMCSA) and PHMSA issued a safety advisory to provide notice of the possibility of catastrophic failure of nurse tanks. This notice focused on nurse tanks manufactured from January 1, 2007, through December 31, 2011, by American Welding and Tank (AWT) at its Fremont, Ohio plant. Nurse […]

Would the risk management program regulations cover the loading and unloading of transportation containers?

The definition of stationary source includes transportation containers used for storage not incident to transportation and transportation containers connected to equipment at a stationary source for loading or unloading (40 CFR Section 68.3). In a January 6, 1998 final rule (63  FR 640), EPA clarified that if a container remains attached to the motive power that

For CAA section 112(r)(1), General Duty, what are the chemicals that are covered?

There is no specific list of substances that subjects a stationary source owner or operator to the general duty provisions. The general duty provisions apply to owners and operators of all stationary sources that have any “extremely hazardous substances”. Extremely hazardous substances are NOT limited to the list of regulated substances listed under section 112(r),

Must separate amounts of regulated substances be aggregated for threshold determinations?

Drums containing regulated substances (listed in 40 CFR §68.130) are stored in several separate locations at a stationary source and there is no possibility that an accidental release in any of the individual storage areas would impact any of the other storage areas. Must the overall amount of the regulated substance present at the stationary

When your “life safety equipment” inspector is violating your HAZLOC requirements!

PLEASE ensure your “life safety” contractor inspector for Exits, Fire Extinguishers, EW/SSs, etc., is FULLY trained on the hazards of the area(s) they will be working in. This year, we have found two (2) national companies that provide these inspection services using electronic devices NOT rated for the hazardous areas where they are working. We

I asked AI to explain why Line Breaks are so hazardous

In an industrial and occupational safety context, a line break accident occurs when workers open pipes, valves, flanges, or vessels containing hazardous materials—such as toxic chemicals, flammable liquids, high-pressure gases, or high-temperature steam—and an unintended release occurs. Because these accidents can result in severe chemical burns, toxic inhalation, explosions, or physical trauma from pressure blasts,

Line Break gone bad (Flammable Gas)

Sinopec Yangzi Petrochemical (May 29, 2026): Four workers died during shutdown maintenance at an ethylene plant in China. The flash fire occurred while operations personnel were disassembling a cracking valve. Early investigations point to incomplete emptying and purging of the pipe, which left residual cracking gases (ethylene, propylene, and butadiene) inside. The suspected ignition source

Seveso Directive Anniversary

July 10, 2026, marks the 50th anniversary of the Seveso chemical disaster in Italy. The European Commission has reaffirmed its commitment to the Seveso Directive, which serves as a global benchmark for industrial safety, while emphasizing the need to adapt to emerging risks like cybersecurity and the energy transition.

Two (2) terms (Blind and Blank) that get misused in energy isolation discussions

First, I am as guilty as anyone for using these terms interchangeably, but this week I was in a deep discussion on PRCS Isolation and those on the other end of the phone were getting confused as I was using these terms interchangeably. So I am setting the record straight on this topic, as it

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