Chemical Process Safety (PSM/RMP)

FRC program – Laundering

Having spent my entire career in Flame Retardant Clothing, I learned that improper laundering could render the PPE useless, maybe even hazardous to wear.  In my time, we always had a contractor launder and maintain our FRC.  It was not cheap, but it was necessary to ensure the PPE worked as intended when we needed…...

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Difference between a hose’s MAWP and it’s “Burst Pressure”

To simplify this, the Maximum Allowable Working Pressure (MAWP) is the maximum pressure at which the hose can operate routinely.  Although, I strongly suggest the “operating ranges” be far less than the MAWP.  However, achieving the MAWP does NOT mean the hose will necessarily fail.  Where the hose will fail is called the “Burst Pressure.” …...

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When does FRC fail it’s user inspection?

The criteria for determining when to retire or repair FR clothing/garments/accessories MUST provide measurable or easily identifiable damage. The following are some means to DEFINE and QUANTIFY these deficiencies:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Go ahead, tell me I’m crazy… but an FRC uniform provider/laundering contractor is a PSM/RMP contractor

In 2023, I began taking issue with the condition of Flame Retardant Clothing (FRC) being used in REQUIRED areas and tasks.  We see garments that in no way would pass a “routine inspection” per NFPA limitations.  My go to RAGAGEP for this is NFPA 2113, Standard on Selection, Care, Use, and Maintenance of Flame-Resistant Garments…...

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Overfill prevention system was not independent of the Basic Process Control System (BPCS) (UK’s HSE)

A Health and Safety Executive (HSE) investigation into a gasoline overfill of a carbon adsorption vapor recovery unit (VRU) revealed concerns with the design of the VRU. The overfill prevention system was NOT independent of the basic process control system (BPCS).  When the BPCS failed the overfill prevention system also failed. This resulted in loss…...

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PSM/RMP Auditing in the 21st Century

OSHA’s PSM standard is over 30 years old, and EPA’s RMP standards/rule is approaching its 30th birthday fast.  They are so 20th century (LOL)!  This article is about how some of my clients are approaching their 3-year audits required by both standards.  This approach embraces the “audit element” of the process safety management system as…...

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Hazards of pneumatic pressure testing in terms of TNT energy

We have discussed the hazards of pneumatic pressure testing many times.  Pneumatic pressure testing should be a “last resort” for pressure testing process equipment.  But for those who question the degree of hazard this REQUIRED test brings about, here is something to consider.  Take a look at the following comparisons between the stored energy in…...

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Why Excess Flow Valves (EFV) fail to close

EPA and OSHA put out an Alert in 2007 regarding the use of Excess Flow Valves (EFV) as a “safeguard”.  Although that alert has been “archived” the failures we see today align with what that alert warned us about 16 years ago!  While excess flow valves (EFV) are in extensive service and have prevented numerous…...

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CGA updates 2.1 – REQUIREMENTS FOR THE STORAGE AND HANDLING OF ANHYDROUS AMMONIA

One of my all time favorite RAGAGEPs is the Compressed Gas Association’s (CGA) 2.1 for those who handle anhydrous ammonia.  This year, they published the 7th Edition, and they made it even better.  Unlike so many RAGAGEPs, the CGA embraced the practice of “Continuous improvement” and really did a nice job with their additional explanations…...

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Hazardous Location Electrical Markings – Material Groups (USCG)

This material is from the United States Coast Guard (USCG) and is an EXCELLENT explanation of the required electrical markings/labels on tools/equipment used within a Hazardous Location. Simply put, if the tool/equipment is NOT marked/labeled for use in the specific HAZLOC, it can NOT be brought into the HAZLOC…. Membership Required You must be a...

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FATAL Pressure Test (BSEE Alert)

On May 15, 2021, an incident resulted in the fatality of an offshore worker when two production personnel were pressure testing a 16-inch well surface casing and anexplosion occurred. The explosion entailed a high-pressure release with no signs of ignition.  Information obtained by BSEE during the subsequent investigation determined that personnel were using a high-pressure…...

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Equipment Opening gone bad (barium sulfide wash cone with a steam line)

NOTE: this was NOT a PSM covered process. OSHA determined the employee — on the job just two months — opened an air intake valve to inspect a noise coming from a barium sulfide wash cone with a steam line that was left open the day before. A rush of cold air in the steam…...

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