Chemical Process Safety (PSM/RMP)

New Safety Policy – Analysis of Secondary Coolant (TECHNICAL SAFETY AUTHORITY OF SASKATCHEWAN)

One way to reduce the risk of an ammonia leak is by monitoring for leakage through the analysis of the secondary coolant (often brine) for signs of ammonia. The secondary coolant in an indirect Ammonia system must be tested no less than twice a year. Information Paper IP-BPV-2021-08-01 outlines the requirements for a secondary coolant analysis that…...

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OSHA defines “Line Breaking”

One of the most dangerous tasks that occur within the battery limits of a covered process is “opening the process.”  This is commonly called a “Line Break” but also applies to vessels.  We won’t find a definition of “Line Breaking” in the PSM Standard; instead, we turn to OSHA’s Permit-Required Confined Space Standards (1910.146 and…...

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Process Safety and OSHA Standards

One of the biggest hurdles for an organization entering OSHA’s and EPA’s process safety standards is that some old OSHA standards are just NOT adequate based on the new level of risks.  This is most noticeable are with flammable liquid processes.  Take, for example, 1910.106, OSHA’s Flammable liquids standard.  It is “OK” for businesses that…...

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Proper installation of ASME Pressure Vessels is key

A licensed contractor installed two newly manufactured vertical machine-mounted air receivers for instrument air processes at a wood treatment facility in November 2020.  During a scheduled maintenance service after eight months of operation, cracks were located on the top head of each vessel, specifically at the head-to-bracket weld fillet welds. The cracking was in similar…...

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600 pound NH3 release from refrigeration process (Ice Rink)

This ammonia refrigeration system for the ice rink had been shut down, and the full ammonia charge (800 pounds) was being stored in the chiller, attached surge vessel, and the oil pot.  Three (3) days before the incident, a contractor was doing maintenance on the brine system to install a pH sensor in the brine…...

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Regulatory Requirements that Satisfy CFATS Risk-Based Performance Standards (RBPS)

The Chemical Facility Anti-Terrorism Standards (CFATS) program requires high-risk facilities to ensure security measures are in place to reduce the risk of more than 300 chemicals of interest (COI) being weaponized. High-risk facilities are assigned to one of four (4) risk-based tiers and must develop a security plan meeting the 18 Risk-Based Performance Standards (RBPS). …...

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RegO issues “WARNING” on Retesting Pressure Relief Valves for ASME Containers

As stated in REGO’s Warning Document… Simply retesting pressure relief valves manufactured by RegO that have been in service for several years to confirm conformance with start-to-discharge and reseal ranges does NOT guarantee that the valve is suitable for continued service. Or that the valve will perform as designed at nominal pressures or in emergency…...

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RegO issues guidance on Pressure Relief Valve Inspection and Maintenance

“Relief valves should be inspected each time the container is filled but no less than once a year. If there is any doubt about the condition of the relief valve, it must be replaced.” Major Factors to determine the “Life” of Relief Valves include: Water/Ice Accumulation Corrosion Dirt – Debris Damage Normal Aging Eye protection…...

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Equipment Opening gone bad (NH3 Heat Exchanger)

On February 19, 2022, Employee #1 took apart an active heat exchanger. While doing this, 419 pounds of ammonia were released, causing upper body burns to the employee. The employee was hospitalized for treatment…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Equipment Opening gone bad (System Applicator)

At 3:10 p.m. on February 2, 2022, an employee, 26, was performing maintenance on a System Applicator. The employee began the ammonia bleeding procedure wearing safety glasses and rubber gloves. After approximately 20 to 30 minutes, the employee no longer heard a whistling sound and believed that the system was completely bled out. When the…...

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HFO-1234yf is still a PSM HHC, even with a revision of the SDS

It seems the games may never end with HFO-1234yf and it’s designation as a Highly Hazardous Chemical (HHC) within the Process Safety Management Standard.  A friend of a friend in the automobile manufacturing industry contacted me about their use of this new refrigerant.  The friend/client shared all of my previous articles explaining how HFO-1234yf is…...

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Draining oil from ammonia refrigeration system using steam leads to catastrophic failure of oil pot and fatality

Employee #1 attempted to replace a leaking oil valve on a minus 30 degree freezer when a tank inside the freezer exploded. The company uses anhydrous ammonia to manufacture ice cream. The liquid ice cream mixture (at 50 degrees) is added to the tank. This freezer was down for seven days, and the tank’s oil…...

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