Chemical Process Safety (PSM/RMP)

Does OSHA’s PSM Standard, 29 CFR § 1910.119 apply to LNG export facilities? No, and here is why…

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:

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

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

A few years ago we were asked to participate in an engineering review/facility siting for a proposed facility.  The business was in a $ crunch so one way they decided to save some $ was to utilize DOT-306 tankers as “temporary storage tanks”, thus reducing the number of above-ground storage tanks AND a reduction in

Back in January 2019, I posted an article titled “Is API 570 your Piping Inspection/Repair RAGAGEP… Repair Requirements are now crystal clear” and this posting caused quite the stir with many of you.  Most of you followed the code(s) and went and verified what I shared in the article, but as usual, I got a

Over the years I have been told time and time again that there are two absolutes in ammonia refrigeration.  #1 – we do not have “temporary operational conditions” so we have no need for “temporary operating procedures” and #2 – there is no “process chemistry” in ammonia refrigeration.  But it dawned on me this week

RMPs must be updated at least once every five years. EPA offers a  Checklist for Submitting your Risk Management Plan (RMP). We must fully update your RMP for resubmission sooner than the five-year anniversary date if any of these changes occur: