Bolted flanges – sweat the small stuff (LPG Jet Fire)
One (1) bolt on a five(5) bolt flange was left loose by just one full turn and we have a small release of a flammable gas… EXCELLENT video by Baker Risk.
Routine and Non-Routine process openings and Chlorine
I do a lot of work in Ammonia and Chlorine, from process safety to emergency response, and the one thing I commonly get asked is why do I write so much about ammonia accidents and not so much about chlorine accidents. Well, to be honest, the vast majority of my chlorine clients are much better
Are you worried about a hydrostatic relief system discharging an HHC/EHS into an occupied space?
For nearly 25 years I have seen CLOSED relief systems used successfully on a multitude of processes involving Extremely Hazardous Substances (EHS) and for many years I have been proposing they be used in the Ammonia Refrigeration industry. The leading trade group for ammonia refrigeration has had a long-standing position against the need for hydrostatic
Hydrostatic Relief on piping systems – why so much hate?
We visit this topic once again as I have already spent time with a “former client” who is now in a serious bind with both OSHA and EPA after a significant Chlorine (Cl2) release. They are a former client as they fired me after a 5-year PHA and 3-year audit a number of years ago.
When 1926.64, OSHA’s PSM standard for Construction would apply
First, let me state that this construction standard has never been cited. This is based on my personal knowledge and the OSHA database; however, it is still in effect and could be cited. Last year, OSHA revised their standards and they simply did away with the duplicate language in 1926.64 and said to follow the
2020 UPDATE on EPA’s Initiative to Improve Safety of Ammonia Refrigeration Facilities in New England
Although anhydrous ammonia is an effective refrigerant, it is also a toxic chemical that can injure or kill people when accidentally released. The death of a worker at a Seafood plant in South Boston in 2016 is the most tragic example recently here in New England. In 2018, the U.S. Environmental Protection Agency (EPA) launched a
When must a facility with an RMP covered process 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 §68.95, which MUST include: an emergency response plan, emergency response equipment procedures, employee training, and procedures to ensure the program is up-to-date. But do all facilities subject
Owner / operator compliance audit timeline
Must an owner or operator conduct and document a compliance audit at the time of an update required under §68.190 if the update is made within three years of the original RMP submission?
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
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
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