Pursuant to the risk management program regulations, facilities must perform an offsite consequence analysis for the worst-case release scenario. Do the quantities of two separate vessels that are interconnected with a closed valve need to be aggregated for the worst-case release scenario analysis?
For the purpose of analyzing the worst-case release scenario required as part of the hazard assessment at 40 CFR Part 68, Subpart B, the worst-case release quantity is identified as the greatest amount held in a single vessel or pipe, taking into account administrative controls that limit the maximum quantity (40 CFR §68.25(b)). Are mechanical
In section 2, element 2.5, of an RMP, facilities must report the quantity of toxic chemical that the facility used for the worst-case analysis. When reporting this data element in RMP*eSubmit for a mixture, should facilities report the entire weight of the toxic mixture potentially being released or only the amount of the regulated toxic
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
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
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
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
