Chemical Process Safety (PSM/RMP)

Those that follow my PSM & RMP Citations / Analysis postings most likely have noticed a significant change in the level and depth that EPA and OSHA are conducting their RMP and PSM inspections.  They have cited many more RAGAGEP issues and now dig deep into PHA’s and SOP’s than they ever had before.  This…...

A contractor was performing rust corrosion removal and prevention services on pressurized piping at a chemical plant in Freeport, Texas. In October 2016, two contractor employees were seriously injured when a pipe ruptured, releasing trichlorosilane. Following an inspection, OSHA issued the contractor a two-item serious citation. The first item, grouped for penalty purposes, alleges violations…...

This is OSHA’s PSM (1910.119) Inpsection Activity for their 2020 Fiscal year (October 2019 through September 2020).  I have broken down the data by # of Citations, # of Inspections, Penalty $’s, and NAICS Industry Classification.  As you can see, OSHA issued 195 citations from 50 inspections for a total of $1,806,072 in fines.  Here…...

Way back in February 2016 I introduced many of you to ISA-RP12.12.03, Standard for Portable Electronic Products Suitable for Use in Class I and II, Division 2 for the first time and I received many e-mails, texts, and phone calls about those 2016 posts.  Although the posts were speaking to smaller electronic devices, most notably “fitness…...

This is awesome. Cavitation has been the end of many pumps in my career and the causes of some significant LOPC events, but to see it be created and watch it in clear pipes and pumps is the way to learn. This short video should be in every operator’s training!!… Membership Required You must be...

No, the employer is not required to include findings and recommendations from the facility siting study report in the same PHA worksheet or recommendations log to comply with 29 CFR § 1910.119(e)(5) and 29 CFR § 1910.119(e)(7)…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

As I always say, we can not discuss MOC and PSSR as if they are separate systems… they go hand in hand 99% of the time.  That is what I want to discuss: how a PSSR requirement defines how we manage our MOC system.  We have discussed many times there are ONLY TWO (2) occasions…...

Buckle up buttercup… the political winds in DC are shifting and with this comes “opportunities” – man how I hate politics!  For those of you who may have thought that the RMP Amendments from the final year of the President Obama administration were long gone – THINK AGAIN!  On Friday (12/4/20), the U.S. Court of…...

This draft guidance document is intended to clarify to the public regarding existing pipeline safety standards. The contents of this document do not have the force and effect of law and are not meant to bind the public in any way, but pipeline operators must comply with the underlying safety standards. (emphasis by me)… Membership...

In the recently released Internation Fire Code (IFC) 2021 edition, the newly designated Section 608 – Mechanical Refrigeration, the code references IIAR 2, 6, 7, 8, and 9 when the refrigerant used is anhydrous ammonia (NH3).  The 2021 edition still has many of the long-time requirements that will apply to NH3 systems, such as “emergency…...