Must a stationary source owner or operator consider the amount of ammonia present in ammonium hydroxide that is contained in a process when determining whether the threshold for ammonia is exceeded? The list of regulated toxic substances at 40 CFR Section 68.130 includes BOTH “ammonia (anhydrous)” and “ammonia (conc 20% or greater)” but does not…...
Under OSHA’s Process Safety Management Standard, an exemption is provided for the atmospheric storage of flammable liquids. Why has EPA decided NOT to include this exemption under the risk management program regulations?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
I have written often about this topic and it is without a doubt the most questioned/challenged topic in my 5-Day Advanced Process Safety course. Several toxic substances are listed as regulated substances under 40 CFR §68.130 with CONCENTRATION QUALIFIERS (e.g., “conc 37% or greater”). The four(4) regulated substances that have concentration qualifiers are: Ammonia (conc…...
The wonderful team of process safety engineers “across the pond” in the UK have published an EXCELLENT and MUST READ guide on how a business can develop their process safety LEADING indicators. This is a MUST READ for those PS Leaders who are looking for ideas on what and how to measure PSM/RMP Leading Indicators. …...
HAZMAT containers used for flammable, corrosive, and toxic liquids and gases will have a pressure/vacuum relief valve to prevent damage to the tank from changes in the internal pressure. These valves MUST be inspected and maintained in line with the manufacturer’s instructions. Some valve designs require a special tool to dismantle them for servicing. Investigations…...
Today I got one of my favorite magazines, of which I have been suggesting everyone in the PSM arena subscribe to (for FREE) – The BULLETIN from the National Board. And in this edition, the NB has an article on the Hanson RV that has an indicator telling when the valve has been activated. These…...
We do a lot of work in flammable atmospheres so yes we have rather high standards for what “minimal compliance” looks like. We recently came across this situation while performing an assessment for a facility that has suffered from a flash fire months earlier. During our walk-thru of the area (they knew we were coming)…...
First, let me say this article was written for those who do NOT live in the world of process safety, but yet they do have hazardous materials on-site in some type of bulk system, albeit below the PSM/RMP thresholds. In this posting, I am going to use Propane/LPG as my HAZMAT as there are many…...
The Ohio Environmental Protection Agency, Division of Air Pollution Control (DAPC) has adopted amended rules in Ohio Administrative Code (OAC) Chapter 3745-104, “Accidental Releases Prevention Program” Rules. The rules in this chapter establish Ohio’s Accidental Release Prevention Program. These rules were promulgated after Ohio received the delegation of authority from USEPA in December 1999 for…...
One of the biggest failures in many “Car Seal” programs is their improper application. I’m not sure where or how this confusion began, but far too many businesses are using car seals well beyond their intended function. Here is a simple way to look at “car seal” programs and how they differ from “servicing/maintenance” programs…...
An amusement park ride is a far cry from a chemical process, but this horrible incident is one we can all learn from! A 6-year old little girl died on September 5, 2021 while riding a drop tower-style ride that uses gravity to create freefall. The two (2) ride operators, which I am assuming were…...
A few years ago I wrote a piece about identifying ALL equipment, especially valves, with a unique identifier. The purpose of that posting was brought about by a lot of facilities challenging our PHA, II, Audit findings/recommendations that all equipment be identified with a unique identifier in the field, on P&ID’s, in SOPs, LOTO procedures,…...
