Chemical Process Safety (PSM/RMP)

Process Safety Information… sweating the small stuff (Flange Bolts/Rods)

In the world of process safety, every little detail adds up; so as one of my favorite bosses always said… “sweat the small stuff”!  This became crystal clear during an incident investigation where a flanged connection was the point of release.  Most people look at a flanged connection as a simple means to connect to…...

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Designed with maintenance in mind, NOT! (Ammonia Refrigeration header detection)

Several years ago, we discussed this picture in terms of a Relief Design Basis, the NH3 vent header sensor placement in terms of NFPA 70 HAZLOC, and the risk of doing maintenance/calibration on the sensor when the process is live.  As usual, I got some nice feedback, and the usual haters chimed in that I…...

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Pressure Testing GONE BAD (Fire Protection System)

On March 6, 2018, a pipefitter (49) was hit in the chest by a pressurized 12-inch diameter polyvinyl chloride (PVC) pipe during a hydrostatic pressure test of a fire suppression system. The sudden pipe movement was attributed to a pipe joint connection failure in a buried section of the pipeline. The failure was due to…...

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A chicken processor loses its appeal regarding MI procedures (j)(2) and inspections (j)(4)

A chicken processor petitioned for review of a determination by the Occupational Safety and Health Review Commission (the “Commission”) that it violated various regulations of the Department of Labor’s Occupational Safety and Health Administration (“OSHA”). We find no error, so we deny the business’s petition.  The Secretary of Labor (“Secretary”) is charged by statute “with…...

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Process safety failures led to the fatal Styrene release in India last month

Today, the Indian government released its investigation findings regarding the fatal Styrene release on May 7, 2020, which killed 12 citizens and hospitalized 585 others.  This incident, like the many before it, came about by a number of failures the facility/company made in the management of their Styrene inventory.  In the light of the root…...

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NH3 2,100 pound NH3 LOPC event exposes eight (8) workers, one hospitalized ($119K)

On January 27, 2019, 12 employees needed transport to nearby hospitals after a a release of 2,100 pounds of anhydrous ammonia.  OSHA cited the facility for failing to: Equip an ammonia refrigeration system with a pressure relief device as referenced by the manufacturer’s operating manual; Train technicians to use an alternative over-pressure safety procedure to…...

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Nitrogen Gas generator for fixed water-based fire suppression systems

Nitrogen… an often misunderstood SAFETY gas that many fear and for good reason!  Imagine you have a flammable liquid that has a Flash-PointP<100°F and you worry about static or other ignition sources causing an event inside your storage container… what can I do to lessen the risk of a fire/explosion in the headspace of my…...

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Fabrication and Field Testing of Refrigerant Piping (ASME B31.5)

One of the most requested slide deck over the years has been from my 5-Day RAGAGEP course, specific to ASME B31.5, Refrigeration Piping and Heat Transfer Components.  The PowerPoint file below is only 12 slides from a 300 slide presentation, but the requirements noted in these 12 slides are often not understood at the plant…...

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OSHA Interpretation on Connected Processes managed by two different companies, but on the same contiguous property controlled by an employer or group of affiliated employers

7/8/20 UPDATE: this LOI was NOT removed from the OSHA website; it was merely MOVED to the Year 2017 LOI Page (Linked Below).  The letter was MOVED without any changes to its content – it was just moved to its proper year.  This was merely a recordkeeping move by OSHA to reflect the year the…...

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Compressor vibration may have caused ammonia leak

On February 18, 2020, the audible alarm and light outside the Ammonia plant was activated at approximately 6:40 pm. The plant operator checked the NH3 (ammonia) readings and it read 43 ppm (parts per million). At 6:45 pm the readings increased to 51ppm and staff activated the Emergency Response Plan, contacted 911, the Chief Engineer,…...

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Ammonia released from a cold storage room evaporator

Two persons received minor injuries from exposure to ammonia after a refrigeration system failed and released ammonia that was intended to be contained within the evaporator and refrigeration system. INCIDENT OVERVIEW The evaporator within a refrigeration system of an industrial food processing facility failed and released ammonia in a cold storage room. Two workers suffered…...

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Improper torque leads to Hydrogen fire and explosion

A hydrogen leak originating from a tank within a high-pressure storage unit serving a hydrogen vehicle fueling station resulted in fire and explosion. Emergency responders were on scene within 7 minutes and contained the fire within 3hours. No damage was reported to the separate forecourt H2 dispenser or to other major station components within the…...

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