How many of you have thought these two images would ever have a place in Process Safety? I use them as visual aids when teaching some of my RAGAGEP courses, as they place a mental image that most can grasp into the students’ heads and provide them with a valid engineering metric they can…...
Have you ever read a RAGAGEP and wished you had been a fly on the wall in the room where a particular requirement was presented and debated amongst the committee members? I have set on my fair share of RAGAGEP committees over the past 20 years and in almost all of muy experiences, when someone…...
As we continue to “dumb down” RAGAGEPs to take away OSHA/EPA’s ability to cite fundamental engineering failures found in processes handling HHC/EHS, the issue of “conflicting requirements” continues to be troubling. As my Anhydrous Ammonia clients learned firsthand last year, with the 7th edition of CGA 2.1, the RAGAGEP has some NEW requirements for pressure…...
Both OSHA and EPA require PSM/RMP facilities to include procedures for “responding to small releases” in their Emergency Action Plans 1910.119(n) Emergency planning and response The employer shall establish and implement an emergency action plan for the entire plant in accordance with the provisions of 29 CFR 1910.38. In addition, the emergency action plan shall…...
A loss of containment and subsequent release of fluids can cause adverse consequences (i.e., impact safety, health, and environment, cause production losses, andincur maintenance and reconstruction costs). The risk analysis should consider the nature of the hazards and ensure that appropriate factors are considered for the equipment items being assessed. Flammable Events (Fire and Explosion)…...
29 CFR 1910.119(f)(1) The employer shall develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
In process safety circles, the word “remote” is found in several codes/standards. In OSHA’s Process Safety Management standard, we find it used in the Normally Unoccupied and Remote Facility (NURF) exemption (1910.119(a)(2)(iii). OSHA did us a favor by officially defining this phrase; however, they have never QUANTIFIED it. Normally unoccupied remote facility means a facility…...
On May 23, 2023, @ 9:00 a.m. Employee #1 and Employee #2, both maintenance workers for a petroleum refinery, were troubleshooting an automated valve in the “Prime G Unit.” Flammable gasoline/hydrocarbons in the piping and flange portion of the automated valve were released, causing an explosion, and fire…. Membership Required You must be a member...
The word “adjacent” may be small in terms of letters used to spell it, but it has an enormous impact on the world of process safety. Both OSHA’s Process Safety Standard (1910.119) and EPA’s Risk Management Plan (Part 68) use the word “adjacent.” Here is how Webster defines “adjacent” adjacent (adjective): not distant: nearby It…...
A great and reliable resource to help comply with… 1910.119(f)(1)(iii)(C) Control measures to be taken if physical contact or airborne exposure occurs; https://www.cdc.gov/chemicalemergencies/factsheets/ammonia.html … Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
This week, OSHA posted an LOI regarding terms used in the PSM Standard, and this LOI has generated some discussions amongst some SAFTENG members, most notably… How are we required to document our HAZLOCs? In OSHA’s LOI, it referenced 1910.307 Hazardous Locations standard which simply states: (emphasis by me) 1910.307(b) Documentation All areas designated as…...
On June 18, 2021, at 6:30 p.m. an employee was working for a firm that operated electric power generation facilities. He was working at a natural gas-fired power plant. He and a coworker were restoring a natural gas filter system at the power plant by aligning valves after a maintenance crew had replaced filter media…....
