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
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 §68.28). What criteria should be used when selecting an alternative release scenario?
