In several of my articles over the years, I have touched on the additional hazards when working with hazardous materials in an elevated position. In my 2016 Line Break presentation @ ASSE Safety 2016, we made a special point to mention how additional safeguards need to be in place when doing line breaks at elevation. …...
UPDATED 09/12/20: OSHA PSM Citations @ food plant (Fatality, NH3 & $107K) Read More »
If there is one common finding in our PSM/RMP audits it is this single requirement for employees who remain to operate critical plant operations before they evacuate. And when we attempt to explain what is actually necessary to just meet 1910.38(c)(3) we are oftentimes met with downright hostility. It is rare these days that anyone…...
The risk management program regulations require the owner or operator of a covered stationary source to develop and implement an emergency response program as described in 40 CFR §68.95, which must include an emergency response plan, emergency response equipment procedures, employee training, and procedures to ensure the program is up-to-date. Do all facilities subject to…...
Which RMP facilities must develop an Emergency Response Program? Read More »
Formaldehyde is not specifically listed with a concentration cutoff, but is listed with the qualifier “solution”. Can the partial pressure exemption be applied to formaldehyde solutions?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
Can the partial pressure exemption be applied to formaldehyde solutions? Read More »
A wise plant manager told me this in my first year in the petrochem industry. I am paraphrasing When it comes to our primary containment systems (he was speaking to piping in this discussion) – if it is not done darn near perfect, all we have to do is wait a while and bad things…...
Process Safety and our primary containment systems Read More »
As I stated last week and posted my updated RMP Audit Checklist ER questions, the RMP ER coordination activities should be at least in your “planning/discussion” phase with your off-site responders/resources. Even though 68.10(b) states that compliance with these activities must be completed by March 14, 2018 and the fact that the amendments did not…...
RMP Emergency response coordination activities effective date Read More »
Back in December 2017, I wrote an article explaining how this new nitrification inhibitor in the ammonia fertilizer industry would impact the facility’s PSM/RMP programs. I received a lot of questions and nasty grams from that article, but one thing I forgot to mention is how this new “blending” operation changes the retail locations EPCRA…...
Anhydrous Ammonia, nitrification inhibitor, and EPCRA Sections 311 and 312 reporting Read More »
For SAFTENG clients and members, I have updated my PSM/RMP audit checklist (the old OSHA PQV checklist) with EPA’s most recent amendment regarding the Emergency Response requirements for Responding and Non-Responding facilities. Keep in mind that these new requirements are “officially” ONLY required when the facility is an RMP facility; if the process(s) is ONLY…...
Updated PSM/RMP Audit Checklist with EPA Emergency Response updates Read More »
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Bolted Flanges – torque with dry/rusty bolts (Video) Read More »
One (1) bolt on a five(5) bolt flange was left loose by just one full turn and we have a small release of a flammable gas… EXCELLENT video by Baker Risk…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
Bolted flanges – sweat the small stuff (LPG Jet Fire) Read More »
I do a lot of work in Ammonia and Chlorine, from process safety to emergency response, and the one thing I commonly get asked is why do I write so much about ammonia accidents and not so much about chlorine accidents. Well, to be honest, the vast majority of my chlorine clients are much better…...
Routine and Non-Routine process openings and Chlorine Read More »
For nearly 25 years I have seen CLOSED relief systems used successfully on a multitude of processes involving Extremely Hazardous Substances (EHS) and for many years I have been proposing they be used in the Ammonia Refrigeration industry. The leading trade group for ammonia refrigeration has had a long-standing position against the need for hydrostatic…...
