The UK’s HSE has published a booklet to help manage risks when performing Hot Work (Welding, Cutting, Brazing) on “used containers”. In the USA, OSHA has some very explicit language in their welding standards… 1910.252(a)(3)(i) Used containers. No welding, cutting, or other hot work shall be performed on used drums, barrels, tanks or other containers […]
I am sharing this report to highlight the weaknesses in the ability of the states to comply with the new emergency response exercise requirements in the RMP rule (40 CFR Part 68.96 Emergency response exercises). In October 2021, the Office of Emergency Management1 (OEM) of the U.S. Environmental Protection Agency conducted a survey of the
Recently a client who uses anhydrous ammonia (NH3) had a significant event involving their NH3. This event is the perfect scenario to demonstrate that “inherently safe design” is by far the best design. The incident involved unloading a tank truck of NH3 into a bulk tank. A single valve was in its CLOSED position when
OSHA has issued an LOI regarding 1910.119(h)(3) Contract employer responsibilities. Here is 1910.119(h)(3) as reference: 1910.119(h)(3) Contract employer responsibilities. 1910.119(h)(3)(i) The contract employer shall assure that each contract employee is trained in the work practices necessary to safely perform his/her job. 1910.119(h)(3)(ii) The contract employer shall assure that each contract employee is instructed in the
Vulnerable zones are areas that could be affected by a release from a chemical accident at a facility subject to the risk management program requirements in 40 CFR Part 68. How can one determine if they live or work within a vulnerable zone?
As part of the hazard assessment, owners and operators of Program 2 and Program 3 covered processes must identify and analyze alternative release scenarios (40 CFR ยง68.28). What criteria should be used when selecting an alternative release scenario?
Many organizations use blinding/blanking as their main means for isolating a Permit-Required Confined Space. But a number of years ago, an unqualified operator mistook a “Paddle Spacer” for a “Paddle Blind,” thus leaving the flammable gas pipe to the PRCS improperly isolated. There is a very distinct way to tell these two in-line devices apart
One of my favorite topics to discuss during hazard analyses, incident investigations involving LOPC, and audits are the use of torque wrenches. These wrenches play a critical role in process safety, yet they may be among the top 5 abused and misused tools in the mechanic’s toolbox. And sadly, many still wish to argue that
Not a trick question; however, I bet it made you stop and think for a second. There are many stories/scenarios involving LOPC events where a pressure gauge was not maintained or not read properly. This year we got involved in an LOPC event and testing done on the critical pressure gauge showed it was way
I took this photo as part of an investigation to assist a potential new client in their defense against an OSHA citation. This setup is exactly what OSHA took issue with. A DOT container “dropped” and was being used as a “storage tank” since its motive power had been removed. This practice caused the PSM
The folks “up north” are miles ahead of OSHA and EPA process safety standards in one simple but HUGE difference… Process Safety Leadership for Senior Management. This standard, not fully embraced by all provinces within Canada, is something that OSHA and EPA should consider adopting in their efforts to revise their compliance standards. This 2022
