Chemical Process Safety (PSM/RMP)

Hazards of filling PIT LPG cylinders (Hydrostatic RV w/ INCORRECT Set Point)

In recent years, we have seen many facilities begin to fill their own PIT LPG cylinders on-site rather than contract this service out. Typically, we find this “change” was poorly managed: no PPE Hazard Assessment, no (or very poor) training on the task, LPG improperly located, improper electrical classification around the LPG tank and the…...

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Is Caustic (NAOH) in your Line/Equipment Opening SWP? ($121K in OSHA citations)

During my time in the process industry, we usually had a “caustic scrubber” attached to our PSM/RMP covered process(s).  This meant this scrubber was “part of” the covered process.  I get a lot of pushback regarding covering “safety critical utilities” that are in place to either PREVENT, PROTECT, or MITIGATE an event from the covered…...

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Line Break gone bad? (High pH solution and Verifying ZES w/o gauge)

We routinely discuss the challenges and risks of performing Line/Equipment Opening (LEO) tasks, with one of the top 5 challenges being the “means used to verify” the pipe/equipment is at a Zero-Energy-State (ZES).  The factors that occurred in this incident probably happens by the hour in the process industry; it is why we ALWAYS have…...

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1998 H2S incident (same contractor; wrong place-wrong time)

Looking at the contractor involved with the refinery H2S incident last week, I came across another refinery accident involving H2S where this contractor had their employees exposed.  I have no special info on this latest incident, and I will let the media release the name of the contractor, but this 1998 incident was being in…...

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CSB releases a new safety video on its investigation into the fatal release of hydrogen chloride

Regardless of what CSB highlights in this video… TORQUE VALUES MATTER and having your Emergency Escape Respirator on your person all played a role in this accident! Also, SIMOPS is a term discussed the video.  CLICK HERE to see a great, and FREE, safety document explaining SIMOPS from our friends at the CCPS. I also…...

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CSB releases a new safety video on its investigation into the fatal release of hydrogen chloride Read More »

CSB releases a new safety video on its investigation into the fatal release of hydrogen chloride

Regardless of what CSB highlights in this video… TORQUE VALUES MATTER and having your Emergency Escape Respirator on your person all played a role in this accident! Also, SIMOPS is a term discussed the video.  CLICK HERE to see a great, and FREE, safety document explaining SIMOPS from our friends at the CCPS. I also…...

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Line Break gone bad (Flammables)

A flash fire broke out at 626 Lynnway on Monday morning after a worker with a private demo company cut a pipe, according to the Fire Department’s Public Information Officer. The worker was transferred to a Hospital with “minor burns.” The worker is expected to make a full recovery.  The worker was carried out of…...

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Line Break fatality with two serious injuries (NH3)

A contract worker died and two others were injured in an ammonia gas leak at a chemical factory. The three (3) contract workers, 24, 37, 24, were working at a chemical factory which was producing soda ash and other products. When they were trying to check an ammonia leak from a pipe around 3.15 p.m.,…...

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UPDATE: EPA’s RMP Hot Work Permit retention period

In 2015 and 2022, I mentioned that the EPA proposed updating 68.85 by requiring Hot Work permits to be retained for five (5) years, where that frequency came from, and why they wanted to update the standard.  Members can read… EPA proposing a retention period for Hot Work Permits and How long do you keep…...

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Top 10 Principles of Managing Organizational Change

The critical issue is that a proposed change’s direct and indirect effects on the control of hazards should be identified and assessed. Due to the greater potential consequences of an accident, major accident hazard sites should aim for greater reliability in their planning and decision-making. Avoid too many simultaneous changes, which may result in inadequate…...

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Refine Non-Destructive Testing to Improve Nurse Tank Safety, Phase III

The FMCSA has begun Phase III of a project to refine the non-destructive metallurgical testing method and protocol for detecting cracks in nurse tanks and to determine possible relationships to causal factors not previously considered in detail. Background:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in...

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Should we STAMP and Sign each official PSM/RMP report?

A client recently underwent an RMP inspection by the US EPA.  One of the issues the inspector took issue with was that the facility did not “certify” their 3-year audit.  This stems from the following: (emphasis by me) EPA RMP § 68.79 Compliance audits(a) The owner or operator shall CERTIFY that they have evaluated compliance…...

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