We have all been there… the auditor identified several “physical changes” during their walk-thru of the process, and when it comes time to audit the MOC element, they begin asking for completed MOCs (and PSSRs). And like everyone before us and mostly after us, we will have made changes that needed a MOC, but we…...
OSHA’s and EPA’s process safety standards require a lot of specific training in order to meet their minimum compliance requirements; however, in this article, I want to point out that although OSHA or EPA makes no specific mention of this training, the training is ABSOLUTELY NECESSARY for a functioning process safety management system…. Membership Required...
After cleaning with steam a tank was quenched with cold water to shorten the cooling time (not normal practice). The tank vent was not calculated for the vacuum resulting from this rapid quenching operation, resulting in a collapsed tank (without liquid release). SOURCE: EPSC Learning Sheet… Membership Required You must be a member to access...
Back in May 2020 and January 2021, I posted the first two parts of this three-part series on the hazards of Liquid Nitrogen. These articles were prompted by the OSHA and State Fire Marshal cases involving fatalities at cattle and human sperm bank businesses. Then, in January of this year, we had the GA Food…...
Does OSHA’s PSM Standard, 29 CFR § 1910.119 apply to LNG export facilities? No, and here is why…… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
How often do the operators within your PSM/RMP covered process(s) actually use their operating procedures? Hourly, Daily, Weekly, Monthly, every three years during refresher training? How often do we think they should be using their operating procedures? How many times have you pulled the SOP binder off the shelf to find it covered in dust…...
In the 2021 revisions to the National Board Part 4 – Pressure Relief Devices, the code formally recognizes the need for an “intervening valve” on the discharge side of a relief valve. The code, section 2.5.6 allows this in the following manner:… Membership Required You must be a member to access this content.View Membership LevelsAlready...
The 2021 NBIC Draft Edition has been officially approved by the NBIC Committee. The list of major changes found below will appear in the 2021 NBIC. The four-part set: Part 1- Installation (162 Pages) Part 2- Inspection (402 Pages) Part 3- Repairs and Alterations (312 Pages) Part 4- Pressure Relief Devices (144 Pages) will cost…...
Much like The National Board did, ASME is now splitting out its relief systems into a new section. The NB created Part 4 – Pressure Relief Devices in 2017 and now ASME is following suit and has created Section XIII, Rules for Overpressure Protection (available 7/31/21). This new section in the 2021 edition of the…...
For 20 years now, when teaching any of my process safety courses I make the student repeat this three times: UPWARDS and UNOBSTRUCTED, UPWARDS and UNOBSTRUCTED, UPWARDS and UNOBSTRUCTED. We do this when we get to the Relief System design basis. The vents to the atmosphere almost will always be required to be UPWARDS and…...
I love the Line Break and Equipment Opening (LEO) SWP because it is one of the most hazardous tasks a worker will perform within a covered process AND the fact that there is no OSHA standard dictating how a business manages these risks. This lack of “OSHA Control” spoon-feeding us safety requirements causes most management…...
Please note this citation was issued as a General Duty Clause (GDC) citation by a State OSHA Plan and the incident was not a PSM/RMP incident (at least OSHA did not cite .119). The practice at issue is one that is done routinely in just about all companies and on just about every type of…...
