Chemical Process Safety (PSM/RMP)

A sealed, unclassified electrical control enclosure, part of a listed and certified force-ventilated commercial hydrogen processing unit enclosure, exploded when the equipment manufacturer’s technician pressed the machine stop switch to complete the factory commissioning procedure. The technician was forcefully hit by the flying metal panel holding the switch and sustained serious injuries requiring lengthy hospitalization […]

At 2:00 p.m. on May 27, 2019, an employee, 19, was preparing to transfer anhydrous ammonia (NH3) from a bulk storage container to a customer-owned double nurse tank. The employee, who was NOT wearing any PPE, opened a valve on the nurse tank before attaching the transfer hoses, causing pressurized NH3 to be released directly

WA-OSHA standards were revised a number of years ago, so they are in “plain English.”  These are a GREAT SOURCE of information for anyone looking for a straight forward explanation of OSHA standard requirements.  One particular standard that I found helpful was its Hazardous Location (HAZLOC) explanations. These hazardous locations are classified as follows:

At 4:30 p.m. on November 11, 2020, two (2) employees were in the process of producing batches of a chlorine dioxide generator inside a newly purchased mixer. Emplo yee #1 was killed in an explosion after closing the lid on the mixer to complete the mixing operations. Employee #2 was injured during the rescue attempt.

OSHA has issued its supplemental VPP assessment questions for 2022.  The questions focus on: Leading Indicators & Mechanical Integrity PSM Metrics/Other MOC & PHA Resident Contractors Ammonia Processes and Refrigeration

Recently a former client was cited for hiring a contractor who was not qualified for the work they were hired to perform.  Also, do not lose sight of the fact that this contractor was NOT cited for any OSHA violation as they did not violate their responsibilities under 1910.119(h)(3), although some may argue they violated

Some chemical warehouses and distribution facilities may be failing to properly manage hazardous chemicals as required by federal law. In the past several years, the EPA has visited numerous chemical warehouses and distribution facilities (i.e., companies that process, formulate, blend, re–package, store, transport, and market chemical products) to determine compliance with the Clean Air Act

EPA is adding natural gas processing (NGP) facilities (also known as natural gas liquid extraction facilities) to the scope of the industrial sectors covered by the reporting requirements of the Emergency Planning and Community Right-to-Know Act (EPCRA), commonly known as the Toxics Release Inventory (TRI), and the Pollution Prevention Act (PPA). 

This has been a huge battle in the power generation and semi-conductor industries!  To me, it is very clear – as soon as the trailer is “dropped”, meaning the semi that was pulling the tube-trailer has been detached, then that trailer becomes a “stationary process”.  EPA has several documents making this point and for those

Formaldehyde is not specifically listed with a concentration cutoff, but is listed with the QUALIFIER “solution”. Can the partial pressure exemption be applied to formaldehyde solutions?

The definition of a process would seem to say that my process is part of the larger company’s process because they are interconnected. Why can’t the larger company just include my process in its RMP?