Chemical Process Safety (PSM/RMP)

FRESH AIR intakes for a ventilation system need to be from a source of FRESH AIR! (Part II)

I am not sure what it is about fresh air intake for exhaust ventilation systems, but we should call them “Rodney”, as in Rodney Dangerfield, because they get no respect.  As I said in 2016 and 2018 in my articles: The Ventilation Design Basis begins with our intakes FRESH AIR intakes for a ventilation system…...

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A food pantry, 50% Hydrogen Peroxide, and DHS’s CFATS

Today a longtime friend and SAFTENG member shared an article in our FaceBook group regarding a food pantry in TN that accidentally gave out fifty-four (54) 1-gallon containers of 50% Hydrogen Peroxide (H2O2) in their food packages.  Now I have no idea what a food pantry is doing with 50% Hydrogen Peroxide, much less that…...

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A PHA is not a JHA; a JHA is not a PHA

Both of these tools are necessary in the process safety arena; however, they have very different and distinct roles in process safety management.  In my career I found it best to perform the PHA first and based on the deviations identified in the PHA, we would write our SOPs to cover those deviations.  And of…...

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More on the limitations of Excess Flow Valves – 9 out 10 times they may let you down when you really need them

Yes… here we go again!  If we wish to claim an Excess Flow Valve as a “layer of protection” against a hose/pipe failure, we then MUST ensure the device is SIZED properly, INSTALLED properly, OPERATED properly, and MAINTAINED properly.  This is what is called process safety management and for the life of me, I just…...

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Flammable Liquids, Combustible materials, and Pressure Vessels

We have had many discussions on SAFTENG regarding pressure vessel safety, but it is the Year 2020 and we need to have a very direct talk about how we manage flammable liquids and combustible materials around our pressure vessels.  In this article, I am primarily speaking to those in the Anhydrous Ammonia fertilizer industry and…...

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Are you an Anhydrous Ammonia distributor using Nitrogen Stabilizers?

If you are an NH3 distributor and you’re using the Nitrogen Stabilizers some things have changed that you need to be aware of.  First and foremost, see my posting with the Safety Alert from Transport Canada regarding the issues they have found regarding storage and transport tanks and these Nitrogen stabilizers.  I have not heard…...

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Safety Advisory: Effects of additives in anhydrous ammonia nurse tanks or delivery tanks (Transport Canada)

In 2017 and 2019 I wrote about these Nitrogen Stabilizers and how their introduction into a PSM/RMP covered process would require a MOC and PSSR and I broke down the potential concerns and questions regarding these additives.  Now it seems there may be a Mechanical Integrity twist to the use of these additives, as Transport…...

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UPDATED 09/12/20: OSHA PSM Citations @ food plant (Fatality, NH3 & $107K)

In several of my articles over the years, I have touched on the additional hazards when working with hazardous materials in an elevated position.  In my 2016 Line Break presentation @ ASSE Safety 2016, we made a special point to mention how additional safeguards need to be in place when doing line breaks at elevation. …...

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EAPs and Procedures to be followed by employees who remain to operate critical plant operations before they evacuate (1910.38(c)(3))

If there is one common finding in our PSM/RMP audits it is this single requirement for employees who remain to operate critical plant operations before they evacuate.  And when we attempt to explain what is actually necessary to just meet 1910.38(c)(3) we are oftentimes met with downright hostility.  It is rare these days that anyone…...

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Which RMP facilities must develop an Emergency Response Program?

The risk management program regulations require the owner or operator of a covered stationary source to develop and implement an emergency response program as described in 40 CFR ยง68.95, which must include an emergency response plan, emergency response equipment procedures, employee training, and procedures to ensure the program is up-to-date. Do all facilities subject to…...

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Can the partial pressure exemption be applied to formaldehyde solutions?

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?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Process Safety and our primary containment systems

A wise plant manager told me this in my first year in the petrochem industry.  I am paraphrasing When it comes to our primary containment systems (he was speaking to piping in this discussion) – if it is not done darn near perfect, all we have to do is wait a while and bad things…...

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