Chemical Process Safety (PSM/RMP)

WA-OSHA releases Draft Curriculum Elements for Refinery Safety Training for the Skilled Trades

Under 2019’s ESHB 1817, owners of petroleum refining or petrochemical manufacturing must ensure their contractors and subcontractors use a skilled and trained workforce to perform all on-site construction, alteration, demolition, installation, repair, or maintenance work. The new law is under Chapter 49.80 RCW. A “skilled and trained workforce” means a workforce where all the workers…...

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Kansas Department of Agriculture updates its Anhydrous Ammonia Storage Tank policies (2/13/2021)

The following policy updates apply to anhydrous ammonia storage tanks (tanks) in the state of Kansas as of 2/13/2021.  The state has issued new retirement dates for the “railcars” that have been modified and used as fixed storage tanks for decades. This policy is intended to apply to the Fertilizer Industry within the state.  It…...

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FAILURES of true “facility siting” – our “zoning” process is broken and dangerous!

Having spent my entire safety career in chemicals, I have always been amazed when communities rezone and permit housing developments such as apartments/condos with high density populations within spitting distance of chemical/processing facilities and then the city officials are furious when there is an event that causes disruption in these housing developments.  This story is…...

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Preparing a process for “opening”

One of the most hazardous tasks that take place within a chemical process is the NON-Routine Opening of the process.  And sadly, there are no RAGAGEPs or OSHA standards that establish minimum safeguards for such hazardous activities.  Which I guess in some ways, is better as it has allowed the industry to establish some really…...

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OSHA updates their VPP Application with NH3 Refrigeration questions

If you’re at a facility where the PSM-covered process involves ammonia refrigeration, OSHA has a few specific questions that would like to ask!  These questions are specific to ammonia refrigeration facilities and will be used to evaluate a facility’s readiness to join the world-class ranks of VPP STAR workplaces.  How would you fare with these…...

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Getting to know your toxic end points

How well do you know your RMP chemicals?  I mean really know them.  One of the top questions we have received in the past several years is asking about the RMP chemicals’ toxic endpoints and why EPA uses mg/L instead of ppm.  PPM is a volume-to-volume or mass-to-mass ratio, whereas mg/l is a mass-to-volume relationship. …...

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The hazards of UNSAFE pressure testing

A topic we have discussed many times here and if you have ever attended one of my process safety courses or presentations you have most certainly heard my dissertation on the criticality of pressure testing and leak testing and the fact that these safety-critical functions come with some serious risks, especially if the pressure testing…...

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FM Global to the rescue once again with their Data Sheet 7-45 – Safety Controls, Alarms, and Interlocks (SCAI)

It is the year 2021 and OSHA’s Process Safety Management standard will be 29 years old this May.  Most processing facilities have come a long way in improving their process safety, but most still lack a comprehensive WRITTEN management program for their Safety Controls, Alarms, and Interlocks (SCAI).  These safety instrumented systems (SIS) play a…...

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Why does it matter which ASME B31 section I apply to my piping circuits?

In many PSM/RMP covered facilities we have two different ASME B31 sections applying to different piping and in our work we see a lot of facilities asking… Why does it matter which ASME B31 section I apply to my piping circuits? For example, the plant has an industrial boiler and in that application, they correctly…...

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Sulphuric acid process opening gone bad

An incident involving PLASTIC sulphuric acid piping at a gas plant. Two workers were operating valves on a 1″ polyvinyl chloride (PVC) drain line so they could transfer sulphuric acid from a storage tank. They were following a written procedure, had held a tailgate meeting to discuss the hazards and emergency procedures, and had all…...

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NEW 2021 standard for NH3 refrigeration systems in Alberta Canada

In response to the tragic 2017 incident in which several people were killed by exposure to ammonia at an ice arena in Fernie, British Columbia, ABSA is now extending the scope of the plant registry to include ammonia refrigeration plants and they just published new guidance and establishes requirements for the ammonia-bearing refrigeration systems operating…...

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