Chemical Process Safety (PSM/RMP)

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

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

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

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

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

Safety and Seperation Distances

From “facility siting” in a PHA to establishing emergency “assemble areas,” the methodology we use matters.  Many of us use a RAGAGEP from The European Industrial Gases Association (EIGA) titled Methodology for Determination of Safety and Separation Distances.  The “safety distance” is to provide a minimum separation that will mitigate the effect of any foreseeable

CSB Releases Final Report into 2021 Fatal Vapor Explosion and Fire at Yenkin-Majestic Facility in Columbus, OH

Today the U.S. Chemical Safety and Hazard Investigation Board (CSB) released its final report on a flammable vapor explosion and fire at the Yenkin-Majestic facility in Columbus, OH, on April 8, 2021. One employee died during the incident, and eight other workers were injured. The CSB’s final report makes several important safety recommendations to Yenkin-Majestics,

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