For several editions, the IFC has incorporated a “Performance-Based Design Alternative” to comply with the requirements of Part V—Hazardous Materials (Chapters 50-67). This was initially added so that facilities already doing PSM/RMP could show compliance with the state fire code without any additional work. In the 2021 edition of the IFC, this alternative has been […]
In FY 2022, the agency continued its efforts to reduce risks of accidental releases at industrial and chemical facilities, such as: Concluded three (3) judicial actions, 145 administrative penalty actions, and 18 administrative compliance orders In FY 2022, EPA renewed its presence in the field and increased its on-site inspections by more than 150% compared to
OSHA’s VPP efforts in process safety has offered the following questions regarding the PSM activities in the process. Here are seven questions that will help you gauge your level of PSM expectations related to ammonia refrigeration:
Mr. Trevor Kletz is, without a doubt, my favorite author. In 2001 he published his book on Human Factors in process safety – “An engineer’s view of human error” (Third edition). It is a MUST-READ for those who practice process safety, significantly if you facilitate process hazard(s) analysis (PHA), including the Human Factors analysis. His
Over the last several years, OSHA has asked, in the annual Supplement B questionnaire, specific questions designed to help share information about the site’s safety and health management systems (SHMS), but mainly about the critical areas of PSM programs and established procedures used to maintain, collect, and analyze PSM systems/process metrics. In 2016, OSHA developed
Relief systems include, but are not limited to, relief valves, relief headers, relief drums, and rupture disks. Design basis means documenting how the loads and sizes of the relief system and inlet and outlet sizes were determined. This includes:
Last month I posted Exhaust Ventilation for Flammable Atmospheres and “Safe Locations” to explain the hazards of not controlling our flammable vapors associated with the required exhaust ventilation. I received several comments and questions on that article regarding the normal process of venting hazardous materials and how to best define a “safe location” for these
I am always amazed to hear people complain about the degree of our auditing. Most clients hire us for detailed auditing, but some see the PSM/RMP 3-year audits as a “check-the-box” exercise and do not appreciate our auditing skills and experience (LOL). Comments/Questions like… “Would OSHA really cite for that?” are commonplace. Let me be
This topic can be hotly contested by some; why is beyond me. Some businesses get lazy in their approach to process safety and convince themselves that flanged piping is cheaper (and easier) than joining the pipes using welding methods. As we have discussed, welding our PRIMARY CONTAINMENT system, such as the piping, comes with many
I can not think of a single business that operated and maintained a PSM/RMP-covered process that did not utilize LOCTITE®. It is a beautiful product; however, it may be the most overused and abused product within the covered process. When used PROPERLY and per Henkel’s instructions, the product works well. But like most really good
You know businesses are cutting costs when I get this question. But it is a good question as we have come across “reclaimed piping” being used in a lesser-degree hazard (e.g., flammable gas to flammable liquid) process. I personally never experienced this practice in my time in industry, but it has become more popular as
One of the most heated debates in the process safety arena is… Do I have to have an emergency response team? EPA has worked to answer this question by designating facilities as “responding” and “Non-responding” facilities. Here is a nice flow chart to help…
