Chemical Process Safety (PSM/RMP)

Recently, several fires occurring during hot work have been reported to BSEE. Hot work is any job with the potential to create an ignition source, such as an open flame, sparks, or high temperatures. Examples of hot work include welding, using acetylene torches, and grinding and cutting metal…. Membership Required You must be a member...

Bureau of Safety and Environmental Enforcement field personnel have indicated a need for increased operator awareness when using temporary equipment (TE). Some TE may be a potential ignition source and can range from small items such as portable welding sets to large skid-mounted packages (e.g., temporary generators, air compressors, hydraulic power packs, well-testing equipment, process…...

In my discussions with SAFTENG members who are Process Safety clients, the question is always asked:  “Where do you get the terms “responding facilities” and “Non-Responding facilities” from?  These are terms used in EPA’s Risk Management Plan rule, and I have said many times in my writings that not every facility is required to have…...

The requirement to issue a hot work permit, including documentation of necessary fire protection and prevention measures, is currently in the RMP regulation only for Program 3 processes. Under 40 CFR 68.85(b), “The permit shall be kept on file until completion of the hot work operations.” Under the existing RMP regulations, it can be difficult…...

EPA initially looks to the latest version of industry codes, standards, and guidelines to determine whether an owner or operator has documented compliance with RAGAGEP under 40 CFR 68.65(d)(2), given that 40 CFR part 68 does not define the phrase “recognized and generally accepted good engineering practices.” EPA believes this application makes sense because the…...

The current definition of “retail facility” at 40 CFR 68.3 is “a stationary source at which more than one-half of the income is obtained from direct sales to end users or at which more than one-half of the fuel sold, by volume, is sold through a cylinder exchange program.” The period of sales to end…...

Currently, under 40 CFR 68.3, the term “stationary source” does NOT apply to transportation activities, including storage incident to transportation for any regulated substance or any other extremely hazardous substance.  A stationary source does include transportation containers connected to loading/unloading equipment or used for storage, not incident to transportation. Still, the term “storage, not incident…...

Ammonia (CAS# 7664-41-7) is an Extremely Hazardous Substance (EHS), listed at 40 CFR Part 355 Appendix A  EPA website and Appendix B with a reportable quantity (RQ) of 100 lbs. Both ammonia and ammonium hydroxide (CAS# 1336-21-6) are listed as Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) hazardous substances at 40 CFR 302.4. Under…...

The RMP Amendments, finalized on January 13, 2017, included a requirement for owners or operators of a stationary source to engage in emergency response coordination activities (40 CFR §68.93). The regulatory text in 40 CFR §68.10(b) states that compliance with these activities must be completed by March 14, 2018. Because the RMP Amendments were not…...

Most formally educated or well-trained safety professionals are familiar with the Hierarchy of Controls.  We use this approach daily in our work to reduce the likelihood of an event and/or the event’s severity.  Mr. Kletz always had a different take on using this philosophy in process safety and as always – he nailed it!… Membership...