Chemical Process Safety (PSM/RMP)

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:

The Ammonia Safety Awareness Program was developed due to the rise of ammonia-related incidents and hazards over the past few years, including the tragedy at Fernie Memorial Arena.  Developed in collaboration with industry professionals, this program provides training and downloadable tools to fill in knowledge gaps and share best practices for maintaining ammonia refrigeration equipment and

This topic has always been one that seemed to be controversial in the ammonia refrigeration sector, with decades of denial that Stress Corrosion Cracking could occur in an ammonia refrigeration process due to the water content in the ammonia.  But last month, Technical BC (British Columbia) discussing their SCC concerns related to pressure vessels in

One of the biggest and longest debates in process safety circles is the responsibility of businesses to upgrade their process design(s) based on an updated RAGAGEP.  OSHA attempted to address this in a 2016 LOI.  Now EPA has stated their “official position”… (emphasis by me)

At least every five (5) years a Risk Management Plan must be updated.  We are seeing a lot of RMP that have been updated in the past 12-16 months that failed to include this in their update.  I wrote about this new requirement this past weekend, but now I want to demonstrate the “fall-out” from

On August 21, 2011, Forty-seven (47) employees, 38 from the primary employer and nine (9) from a secondary temporary agency, were sent to hospitals for treatment of respiratory irritation after being exposed to chlorine dioxide released inside a tomato processing plant. Three (3) employees were admitted for further treatment. The chlorine dioxide release was due

Respondent is the owner of the meat processing facility which utilizes anhydrous ammonia, a hazardous substance, at the Facility.  From December 28-30, 2017, Respondent inadvertently released approximately 1,700 pounds of ammonia due to a faulty isolation valve in the Facility’s refrigeration system (“the Release”). On December 13, 2018, EPA conducted an inspection of the Facility