Chemical Process Safety (PSM/RMP)

PHMSA issues guidance on NH3 Nurse Tank Non-Destructive Testing

In February 2024, the Federal Motor Carrier Safety Administration (FMCSA) and PHMSA issued a safety advisory to provide notice of the possibility of catastrophic failure of nurse tanks. This notice focused on nurse tanks manufactured from January 1, 2007, through December 31, 2011, by American Welding and Tank (AWT) at its Fremont, Ohio plant. Nurse…...

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Pressure testing piping and the connected vessels

Every once in a while, I come across a process design that leads to code issues down the road. This usually occurs with small pressure vessels (e.g., less than 5 cubic ft) that fall outside the scope of ASME Section VIII and also fall outside the scope of being a “confined space” (e.g., too small…...

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Would the risk management program regulations cover the loading and unloading of transportation containers?

The definition of stationary source includes transportation containers used for storage not incident to transportation and transportation containers connected to equipment at a stationary source for loading or unloading (40 CFR Section 68.3). In a January 6, 1998 final rule (63  FR 640), EPA clarified that if a container remains attached to the motive power that…...

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For CAA section 112(r)(1), General Duty, what are the chemicals that are covered?

There is no specific list of substances that subjects a stationary source owner or operator to the general duty provisions. The general duty provisions apply to owners and operators of all stationary sources that have any “extremely hazardous substances”. Extremely hazardous substances are NOT limited to the list of regulated substances listed under section 112(r),…...

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Must separate amounts of regulated substances be aggregated for threshold determinations?

Drums containing regulated substances (listed in 40 CFR §68.130) are stored in several separate locations at a stationary source and there is no possibility that an accidental release in any of the individual storage areas would impact any of the other storage areas. Must the overall amount of the regulated substance present at the stationary…...

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When your “life safety equipment” inspector is violating your HAZLOC requirements!

PLEASE ensure your “life safety” contractor inspector for Exits, Fire Extinguishers, EW/SSs, etc., is FULLY trained on the hazards of the area(s) they will be working in. This year, we have found two (2) national companies that provide these inspection services using electronic devices NOT rated for the hazardous areas where they are working. We…...

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I asked AI to explain why Line Breaks are so hazardous

In an industrial and occupational safety context, a line break accident occurs when workers open pipes, valves, flanges, or vessels containing hazardous materials—such as toxic chemicals, flammable liquids, high-pressure gases, or high-temperature steam—and an unintended release occurs. Because these accidents can result in severe chemical burns, toxic inhalation, explosions, or physical trauma from pressure blasts,…...

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Line Break gone bad (Flammable Gas)

Sinopec Yangzi Petrochemical (May 29, 2026): Four workers died during shutdown maintenance at an ethylene plant in China. The flash fire occurred while operations personnel were disassembling a cracking valve. Early investigations point to incomplete emptying and purging of the pipe, which left residual cracking gases (ethylene, propylene, and butadiene) inside. The suspected ignition source…...

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PSM and Incident Investigations (Wilfull; $70K)

Citation 2 Item 34 Type of Violation: Willful-Serious29 CFR 1910.119(m)(1): The employer did not investigate each incident which resulted in, or could reasonably have resulted in a catastrophic release of highly hazardous chemicals in the workplace:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Piping MAWP vs Burst Pressure are VASTLY different

Many in safety may not recognize that the “burst pressure” of piping is NOT the same as the Maximum Allowable Working Pressure (MAWP). ASME B31.3 requires the facility to identify and work within the MAWP. For those who may not know the difference and why it matters…… Membership Required You must be a member to...

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Seveso Directive Anniversary

July 10, 2026, marks the 50th anniversary of the Seveso chemical disaster in Italy. The European Commission has reaffirmed its commitment to the Seveso Directive, which serves as a global benchmark for industrial safety, while emphasizing the need to adapt to emerging risks like cybersecurity and the energy transition…. Membership Required You must be a...

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Two (2) terms (Blind and Blank) that get misused in energy isolation discussions

First, I am as guilty as anyone for using these terms interchangeably, but this week I was in a deep discussion on PRCS Isolation and those on the other end of the phone were getting confused as I was using these terms interchangeably. So I am setting the record straight on this topic, as it…...

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