Chemical Process Safety (PSM/RMP)

First, let me state that this construction standard has never been cited.  This is based on my personal knowledge and the OSHA database; however, it is still in effect and could be cited.  Last year, OSHA revised their standards and they simply did away with the duplicate language in 1926.64 and said to follow the…...

Although anhydrous ammonia is an effective refrigerant, it is also a toxic chemical that can injure or kill people when accidentally released. The death of a worker at a Seafood plant in South Boston in 2016 is the most tragic example recently here in New England.  In 2018, the U.S. Environmental Protection Agency (EPA) launched a…...

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. But do all facilities subject…...

Must an owner or operator conduct and document a compliance audit at the time of an update required under §68.190 if the update is made within three years of the original RMP submission?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

In the world of process safety, every little detail adds up; so as one of my favorite bosses always said… “sweat the small stuff”!  This became crystal clear during an incident investigation where a flanged connection was the point of release.  Most people look at a flanged connection as a simple means to connect to…...

On March 6, 2018, a pipefitter (49) was hit in the chest by a pressurized 12-inch diameter polyvinyl chloride (PVC) pipe during a hydrostatic pressure test of a fire suppression system. The sudden pipe movement was attributed to a pipe joint connection failure in a buried section of the pipeline. The failure was due to…...

A chicken processor petitioned for review of a determination by the Occupational Safety and Health Review Commission (the “Commission”) that it violated various regulations of the Department of Labor’s Occupational Safety and Health Administration (“OSHA”). We find no error, so we deny the business’s petition.  The Secretary of Labor (“Secretary”) is charged by statute “with…...

Today, the Indian government released its investigation findings regarding the fatal Styrene release on May 7, 2020, which killed 12 citizens and hospitalized 585 others.  This incident, like the many before it, came about by a number of failures the facility/company made in the management of their Styrene inventory.  In the light of the root…...

On January 27, 2019, 12 employees needed transport to nearby hospitals after a a release of 2,100 pounds of anhydrous ammonia.  OSHA cited the facility for failing to: Equip an ammonia refrigeration system with a pressure relief device as referenced by the manufacturer’s operating manual; Train technicians to use an alternative over-pressure safety procedure to…...

Nitrogen… an often misunderstood SAFETY gas that many fear and for good reason!  Imagine you have a flammable liquid that has a Flash-PointP<100°F and you worry about static or other ignition sources causing an event inside your storage container… what can I do to lessen the risk of a fire/explosion in the headspace of my…...