This question causes quite the debate during our audits/assessments! My record is 27 full-size cabinets in a single control area. It was actually inside a single, but large room that had NO fire ratings. And when I began to question the number and load of flammables in the room, you would have thought I shot […]
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,
At 12:30 am on May 30th, 2020, failure of a 6” pressure piping elbow located on top of a storage tank resulted in black liquor being sprayed onto adjacent buildings, equipment, and ground within an approximately 50m (165′) area. The line from the liquor transfer pump into the top of the tank failed and 74%
To reduce the risk of more than 300 chemicals of interest (COI) being weaponized, the Cybersecurity and Infrastructure Security Agency’s (CISA) Chemical Facility Anti-Terrorism Standards (CFATS) program identifies and regulates high-risk chemical facilities to ensure appropriate security measures are in place. Under CFATS, a chemical facility is “any establishment that possesses or plans to possess
Fertilizer Canada created the Anhydrous Ammonia Code of Practice (Ammonia Code) to provide uniform safety and security practices for the handling and storage of anhydrous ammonia at ag-retail facilities in Canada. The Ammonia Code outlines best practices applicable to the transportation, distribution, storage, and handling of anhydrous ammonia associated with these facilities. The Ammonia Code
This is another case where OSHA and EPA compliance may be the least of our concerns, as this is REAL LIFE process safety – NOT compliance work! Yes, we have to comply with our repair RAGAGEP; but I was referring to whether a facility does a MOC or not. Let’s examine this type of work
