Chemical Process Safety (PSM/RMP)

This advisory clarifies roles and responsibilities for the safe operation and maintenance of registered unattended ice surface refrigeration plants in accordance with the Operating Engineers (OE) regulation (O. Reg. 219/01 or “the regulation) and the corresponding Director’s Order and any applicable OE Alternate Rules. Unattended refrigerated ice surfaces are an important part of Ontario’s recreational…...

The Washington State Department of Labor & Industries (L&I) is proposing updated workplace safety rules for petroleum refineries designed to prevent catastrophic events like the 2010 explosion that killed seven workers at the former Tesoro refinery in Anacortes. The proposed update addresses what’s known as process safety management (PSM), which describes the way workplaces handle…...

This posting is a spin-off of information presented in the white paper from the UK’s Chartered Institute of Ergonomics and Human Factors. That paper focused on concerns with treating human factors in Bowtie’s analysis. I have modified their wording to make their valid points reflect all recognized PHA methodologies. The paper mentions eight (8) concerns…...

EPA recently issued two citations to a juice processing facility for failing to comply with the amended requirements in 40 C.F.R. § 68.93(a) & (c).  On March 21, 2022, an incident at the ammonia refrigeration facility resulted in an accidental release (the “Incident “). Pursuant to Section 114 of the CAA, 42 U.S.C. § 7414,…...

I grew up under the belief that when a PSV lifts, it gets replaced ASAP. However, this practice seems to have changed over the years. So lets see what our RAGAGEP says on the matter…… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

One of the things that EPA learned from OSHA’s roll-out of their PSM standard was that not everyone recognized the standard as a 14-element management system.  So when it came time for EPA to roll out its RMP, they made a “management system” part of its requirements.  However, EPA quickly disappointed when they said all…...

At 3:00 a.m. on July 27, 2022, an employee was bolting a flow meter on a hydrogen cyanide (HCN) line that was dripping fluid with a coworker. The employee stepped away from the job after having difficulty installing the final bolts. The employee waved his hand in front of his face and backed away from…...

When your process safety consultant tells you that “torque” does not matter… after you called him/her to ask about it after you read about torque in the owner’s manual of the component you are getting ready to install… it is time to FIND A REAL PROCESS SAFETY ENGINEER. Torque values are the pinnacle of DEFINING…...

These are just two little words that cause so much debate… “at least.”  Although this is a prevalent phrase found in many Recognized and Generally Accepted Good Engineering Practices (RAGAGEP), I have found it to be one of serious debate, and it should NOT be.  First, lets see how dictionaries officially define the phrase: at…...