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 […]
PTFE-lined piping, such as the equipment installed in the HCl regeneration unit, requires a retorquing of flange bolts to minimize leakage from bolt relaxation. The retorquing involves bringing the processing unit to operating temperature, allowing it to cool to ambient temperatures, and retorquing to the set value. As the original equipment manufacturer (OEM) describes: A
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…
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
The registration process for RMP*eSubmit Certifying Officials recently changed to use additional CDX registration features. The below changes went into effect on Friday, February 24, 2023. Please note that no immediate action is necessary unless one of your facilities has an upcoming anniversary date or need for a resubmission, correction or a first time submission. Identity
Can a PSM/RMP facility be “compliant” with its piping RAGAGEPs (B31 series) if the facility does not have a piping “inspector”? When many hear the phrase “piping inspector,” they immediately think of the Mechanical Integrity element; however, the ASME B31 series also uses the phrase, and it refers to the installation of piping per the
The latest NTSB Safety Alert can be applied to Process Safety! It speaks to the critical nature of “joinment” using a B-nut on fuel, oil, and air lines on aircraft. It also addresses over-torquing or under-torquing as a failure mode for this joint. A B-nut is a common term for a nut that provides the
Senators Markey and Warren and Congressman Moulton have sent a letter to Seqens North America seeking a response to many questions regarding the business’s past accidents and compliance issues. In the early hours of Thursday, May 4, 2023, an explosion at the Seqens pharmaceutical manufacturing facility in Newburyport injured four workers, with a fifth worker
