Chemical Process Safety (PSM/RMP)

The Ohio Environmental Protection Agency, Division of Air Pollution Control (DAPC) has adopted amended rules in Ohio Administrative Code (OAC) Chapter 3745-104, “Accidental Releases Prevention Program” Rules. The rules in this chapter establish Ohio’s Accidental Release Prevention Program. These rules were promulgated after Ohio received the delegation of authority from USEPA in December 1999 for…...

One of the biggest failures in many “Car Seal” programs is their improper application. I’m not sure where or how this confusion began, but far too many businesses are using car seals well beyond their intended function. Here is a simple way to look at “car seal” programs and how they differ from “servicing/maintenance” programs…...

An amusement park ride is a far cry from a chemical process, but this horrible incident is one we can all learn from! A 6-year old little girl died on September 5, 2021 while riding a drop tower-style ride that uses gravity to create freefall.  The two (2) ride operators, which I am assuming were…...

At 12:30 am on May 30th, 2020, failure of a 6” pressure piping elbow located on top of a storage tank resulted in black liquor being sprayed onto adjacent buildings, equipment, and ground within an approximately 50m (165′) area. The line from the liquor transfer pump into the top of the tank failed and 74%…...

To reduce the risk of more than 300 chemicals of interest (COI) being weaponized, the Cybersecurity and Infrastructure Security Agency’s (CISA) Chemical Facility Anti-Terrorism Standards (CFATS) program identifies and regulates high-risk chemical facilities to ensure appropriate security measures are in place. Under CFATS, a chemical facility is “any establishment that possesses or plans to possess…...

Fertilizer Canada created the Anhydrous Ammonia Code of Practice (Ammonia Code) to provide uniform safety and security practices for the handling and storage of anhydrous ammonia at ag-retail facilities in Canada. The Ammonia Code outlines best practices applicable to the transportation, distribution, storage, and handling of anhydrous ammonia associated with these facilities. The Ammonia Code…...

This is another case where OSHA and EPA compliance may be the least of our concerns, as this is REAL LIFE process safety – NOT compliance work!  Yes, we have to comply with our repair RAGAGEP; but I was referring to whether a facility does a MOC or not.  Let’s examine this type of work…...

Although I agree with most of EPA’s FAQs regarding their RMP standard, this one is just sad!  The question was asked… Are Mechanical Controls Considered Administrative Controls? EPA and I could not be further apart on this topic, as EPA actually stated they would NOT accept an engineered hi-level alarm/interlock and would only accept a…...

EPA will, according to the regulations at 40 CFR §68.220(b), select stationary sources for audits based on any of the following criteria:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

The prevention program requirements under 40 CFR Part 68, Subparts C and D, include “hazard reviews” and “process hazard analyses”. Is a “hazard review” synonymous with a “process hazard analysis” (PHA)? No, and here is the difference…… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

If an incident caused by theft or other criminal activity at a covered facility resulted in or could reasonably have resulted in a catastrophic release of a regulated substance, then the owner or operator of the covered facility must perform an incident investigation. If it would be unreasonable, based on the owner/operator’s knowledge of the…...