When writing SWPs/SOPs be sure how you phrase things. KNOW your audience. An elementary teacher got what she asked for when she simply asked the class to draw a clock showing the time as 10 minutes past 11. This exercise is called the Clock Drawing Test for Cognition. Usually reserved for the elderly or someone […]
“The Natural Gas facility lacked a formal PSV testing procedure that included a QA/QC process to ensure that PSV’s are properly returned to service after testing with isolation valves car–sealed in their correct positions. At the time of the Incident, operators were trained to assist with PSV testing by observing another more experienced operator and
Preliminary investigation indicates that two (2) HVAC contractors were in the vicinity of the ammonia leak when it was initiated. Norwood’s first responders were able to stabilize and transport one man to Good Samaritan Medical Center, and he was then further transferred to Massachusetts General Hospital for specialized treatment. The second contractor, 68, was deceased
I have written numerous times about how the PSM/RMP thresholds are inconsequential regarding line/vessel opening hazards. A 1/2″ line in a water treatment process, NOT covered by PSM/RMP as it ran on 150# cylinders, poses the same risks as if the 1/2″ line was part of a covered process. Granted, the LOPC event could release
On May 26, 2022, a crew was in the process of cutting up and disassembling two ammonia refrigeration systems (referred to as P24 and P34 in this report) at an ice distribution facility located in the Mount Paul Industrial Park located in Kamloops, British Columbia. Those present understood that ammonia had been previously removed from
At 8:42 p.m. on February 19, 2022, Contractor #1 was taking apart an active heat exchanger. While doing this, 419 pounds of ammonia were released, causing upper body burns to an the contractor. Two contractors and one employee went to the hospital. The contractor was hospitalized for treatment.
I am always amazed at how far facilities will go to “exclude” contractors from their PSM/RMP contractor program. One that is a very common exclusion is “painting contractors”. Here is an example of how the WRONG painting contractor, provided with a bad scope of work, can cost you more than you bargained for…
Back in my time, we could use phrases like “dumb as a post,” and people were not offended, and they clearly understood what you were trying to convey. I often think back to that statement when I think about bollards—such a simple, effective means to protect critical assets when designed and installed PROPERLY. Many seem
The existing PSM standard (1910.119) applies in part to processes involving a flammable liquid or gas on site in one location in a quantity of 10,000 pounds or more. However, the existing PSM standard contains an exemption for “[f]lammable liquids stored in atmospheric tanks or transferred which are kept below their normal boiling point without
The potential changes of scope include: Clarifying the exemption for atmospheric storage tanks Expanding the scope to include Oil- and Gas-Well Drilling and Servicing Resuming Enforcement for Oil and Gas Production Facilities Expanding PSM coverage and requirements for reactivity hazards Updating and expanding the list of HHCs in Appendix A of the existing PSM standard
In OSHA’s fiscal year 2022, Management of Change was the #6 most cited element of the PSM standard. Here is a breakdown of those citations…
In OSHA’s fiscal year 2022, Contractors was the #5 most cited element of the PSM standard. Here is a breakdown of those citations…
