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
Although I agree with most of EPA’s FAQs regarding their RMP standard, this one is just sad! The question was asked… Are Mechanical Controls Considered Administrative Controls? EPA and I could not be further apart on this topic, as EPA actually stated they would NOT accept an engineered hi-level alarm/interlock and would only accept a
EPA will, according to the regulations at 40 CFR §68.220(b), select stationary sources for audits based on any of the following criteria:
The prevention program requirements under 40 CFR Part 68, Subparts C and D, include “hazard reviews” and “process hazard analyses”. Is a “hazard review” synonymous with a “process hazard analysis” (PHA)? No, and here is the difference…
If an incident caused by theft or other criminal activity at a covered facility resulted in or could reasonably have resulted in a catastrophic release of a regulated substance, then the owner or operator of the covered facility must perform an incident investigation. If it would be unreasonable, based on the owner/operator’s knowledge of the
One of the top questions we get and it goes to HAZARDOUS MATERIALS MANAGEMENT! We have an EHS/HHC on site and today we are under the PSM and RMP TQ’s – KEEPING in mind that the standards have different TQ’s for many of the EHS/HHC’s. But if we do not manage these inventories AND cap
I have had seen dozens of facilities covering (albeit very poorly) a process that is NOT a PSM/RMP covered process because some consultant told them it was. The consultant(s) would point to an old statement by EPA that the Threshold Quantity (TQ) determination was based on the process’s ability to hold an amount exceeding the
EPA attempts to define and quantify how far apart separate vessels have to be to be considered different processes. There is no hard-and-fast rule for how great this distance should be before you can consider the vessels as part of one process.
