Chemical Process Safety (PSM/RMP)

IFC and Hot Work Signage

As you know, I am a big fan of the International Fire Code and utilize it more than outdated OSHA standards. One requirement the IFC has that OSHA does not is that “conspicuous signs shall be posted to warn others before they enter the hot work area.” Such signs shall display the following warning:… Membership...

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Hot Work on “used containers”, including process vessels, results in two workers receiving life altering injuries

On 20 September 2017, two employees of were using a grinder to cut and replace pipework at the top of an 11-metre (40’) high metal tank containing waste slurry. They were not using harnesses. Sparks from the grinder ignited flammable gasses causing the tank to explode. The slurry vessel was airborne for 9 seconds and…...

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Hazards of Pneumatic Pressure Testing/Leak Testing (Fatality)

On March 20, 2024, at noon, an employee, 34, was pneumatically leak-testing a newly installed 56-inch drainpipe. The pipe extended from one side of the street to the other, roughly 150 feet. They placed a rubber pressure plug on one side and another on the testing site across the street. At about 30 minutes into…...

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CSB updates H2S Line Break Double Fatality – Contractor(s) Opened WRONG flange

Today, the U.S. Chemical Safety and Hazard Investigation Board (CSB) released an update on the agency’s investigation of a fatal release of toxic hydrogen sulfide gas at the PEMEX Deer Park Refinery in Texas on October 10, 2024, which killed two workers and injured 13 others. PLEASE UNDERSTAND we may know WHAT happened, but we…...

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A look inside the Caramel Processing area

Last week, we saw the devastation of a catastrophic failure of a pressure vessel (PV) in Louisville, KY. We still do not know the cause of this failure, just that it was a “cook vessel #6. SAFTENG members can see my breakdown of the photographic evidence available from the Courrier Journal (local Louisville newspaper). But…...

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Line Break/Equipment Opening GONE BAD (185F water)

Another example shows us that serious hazards can be found OUTSIDE of chemical processes, and applying the Line Break/Equipment Opening Procedure and Permit to these hazards could go a long way in controlling these recognized hazards. DEFINING and QUANTIFYING “hazardous energy” sources is STEP 1 in ensuring the process/system can be safely opened. Step 2…...

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True Facility Siting – Louisville Explosion

This Louisville explosion has started the debate about the plant being in a residential area. What most of the media and local politicians fail to mention is that the plant has been there since 1948. The neighborhood was allowed to build up around it because of lax zoning and spineless politicians. So to blame the…...

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My take on Louisville Explosion

The Courier-Journal has released more photos. Below is my analysis of these photos, using their and Google Maps road images. The first image below is the PRE-EXPLOSION image. In it, we can see the two (2) standing cooling towers/condensers. The one in the blue box is the one that was destroyed and came to rest…...

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Catastrophic Failure of Pressure Vessel (Again?)

This week, we saw a fatal explosion in Louisville, KY. This same facility, albeit under a previous ownership, had a catastrophic failure of a PV in 2003. The photos coming out of the post-analysis of this week’s event look to be a similar type of explosion. CLICK HERE to see the pics. Here is my…...

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EPA RMP FY 2024 PARTIAL YEAR RESULTS

Inspections As of the 3rd quarter of the fiscal year (Q3), EPA completed 133 CAA Section 112(r) (Risk Management Program) inspections. Enforcement Cases As of the 3rd quarter of the fiscal year (Q3), EPA took action at 73 facilities to decrease the likelihood of chemical accidents.  Sasol Chemicals: In April 2024, EPA finalized a settlement…...

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EPA’s RMP Emergency Drills vs. International Fire Code Drill Requirements

The EPA’s revisions of its Risk Management Plan requirements regarding emergency drills have gotten much attention.  However, they were always a bit behind when it comes to the International Fire Code.  And need I remind those of you reading this that many states have adopted the IFC in some form. A Group H occupancy is…...

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