In recent months we have seen some reductions in workforce across several clients. Some of these clients are very mature in their approach to safety management, and others are not quite there yet. In those businesses with a mature Safety Management System (SMS), one of these facilities is NOT a PSM/RMP facility – but they…...
At 1:00 a.m. on January 19, 2019, Employee #1, 45 years old, employed by a plumbing company, was working at a refinery. He was removing a blind flange in preparation for installing 2-inch piping to a 2-inch line in the MHF Alkylation unit. When the flange was unbolted…… Membership Required You must be a member...
I had the pleasure of teaching another Advanced Course on Process Safety (40-hr). When discussing Relief Systems, their design, and their RAGAGEP(s), the UPWARDS and UNOBSTRUCTED piece got many questions. ALL RAGAGEPs regarding PRDs will state “UPWARDS and UNOBSTRUCTED” or similar language. Even the older OSHA standards uses the phrase “Upward and Unobstructed” in the…...
At 12:30 p.m. on January 31, 2023, Employee #1, 45, performed cathodic protection maintenance on a 4-inch natural gas pipeline. Employee #1 removed the resin coating off the external portion of the pipeline to test the hull thickness of the pipeline. While removing the coating, the pipeline exploded. Employee #1 was killed by immolation. Employee…...
One of the worst injury accidents of my career occurred in a PSM/RMP-covered process but involved a non-HHC/EHS. The chemical was “hot caustic,” a byproduct from the process used in another process’s scrubber. A sister facility had an incident in which it was discovered that the caustic was too weak. Thus in a process upset,…...
I came across these helpful tips for our Safe Work Permitting System. I hope it can help others…… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
This past week, we saw the 2nd catastrophic failure of an NH3 nurse tank in three months. This is indeed a rare occurrence. Both incidents appear (from news accounts and photos) to be circumferential weld failures on these vessels. Both vessels failed while they contained NH3 (levels unknown), but neither was actively being filled at…...
One of the most common valves used in industrial settings is the 1/4-turn ball valve. From 1/4″ up to 6″, these valves are everywhere, regardless of the risks they may pose. Recently a client and I discussed these valves and their risk in highly hazardous chemical processing. I have had several incidents over my career…...
On June 27, 2022, an employee at a packaging plant was flushing a chlorine dioxide pump for maintenance when some of the chlorine dioxide escaped the process and he inhaled it. The employee was rushed to the hospital and later died…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member?...
In the world of Human Factors, we have a saying, “failing safely,” which translates into… all humans make mistakes – it’s our job to identify those error/mistake traps and design work to lessen those error opportunities. In Process Safety we used to use the phrase “cascading failures”, which is the opposite of “failing safely.” In…...
As of July 28, 2023, Congress has allowed the statutory authority for the Chemical Facility Anti-Terrorism Standards (CFATS) program (6 CFR Part 27) to expire. Therefore, CISA cannot enforce compliance with the CFATS regulations at this time. Due to this lapse in statutory authority, CISA cannot enforce compliance with the CFATS regulations. Access to the…...
Notice I used the word “necessary” and not the word required. In my experience, a PSSR saved my ass plenty of times when OSHA/EPA did NOT require it. To my knowledge, OSHA (nor EPA) have defined the word “facilities” in the context they used it in 1910.119(i)(1)… (emphasis by me) 1910.119(i)(1) The employer shall perform…...
