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 […]
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
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
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
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.
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
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
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?
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
As I stated last week and posted my updated RMP Audit Checklist ER questions, the RMP ER coordination activities should be at least in your “planning/discussion” phase with your off-site responders/resources. Even though 68.10(b) states that compliance with these activities must be completed by March 14, 2018 and the fact that the amendments did not
Back in December 2017, I wrote an article explaining how this new nitrification inhibitor in the ammonia fertilizer industry would impact the facility’s PSM/RMP programs. I received a lot of questions and nasty grams from that article, but one thing I forgot to mention is how this new “blending” operation changes the retail locations EPCRA
For SAFTENG clients and members, I have updated my PSM/RMP audit checklist (the old OSHA PQV checklist) with EPA’s most recent amendment regarding the Emergency Response requirements for Responding and Non-Responding facilities. Keep in mind that these new requirements are “officially” ONLY required when the facility is an RMP facility; if the process(s) is ONLY
