Chemical Process Safety (PSM/RMP)

Fraud Alert: Notice of Violation Letter Phishing Scam

The U.S. Environmental Protection Agency Office of Inspector General is issuing this fraud alert to highlight an increasingly common phishing scam involving fraudulent EPA Notice of Violation letters. In this scam, a fraudster sends a falsified EPA Notice of Violation letter to a target business and requests that the business respond by phone or email…....

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Chemical Safety Board (CSB) updated its published list of reported chemical release incidents

The Chemical Safety Board (CSB) updated its published list of reported chemical release incidents. These are not incidents that the CSB is investigating, these are incidents that were reported to the CSB under their Accidental Release Reporting rules (40 CFR 1604)…. Membership Required You must be a member to access this content.View Membership LevelsAlready a...

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CSB Releases New Study Calling for Greater Use of Remote Isolation Equipment at Chemical Facilities

I love the CSB’s work, but this study could have been said in really simple terms… State Fire Code(s)!  I have written dozens of articles explaining the specific requirements of the International Fire Code (IFC), from which most of the 50 states have adopted some “revised” version.  Chapter 50 of the IFC (and those states…...

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Fatal HW Explosion on Aqua Ammonia Storage Tank

Many thanks to my friend in safety down under, Mr. Peter Hunt, Director and Principal Consultant, Whamcorp Pty Ltd On 25 March 1991, a contractor died after an ammonia tank he was upgrading exploded at the ICI plant. BACKGROUND… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log...

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The journey of the “lazy bollards” (what we call bollards that just don’t work!)

The Hydrant and PIV must be protected, so we installed two (2) “lazy bollards.” The post are correct, their installation is NOT to code. Had they been installed in the parking lot with a 15” diameter footing and at a height of 4’ AND 4’ away from the PIV, then all would be OK. But…...

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Manufacturer’s Limitations of Sulphur Sticks

In 2012, I discussed the use of sulfur sticks and asked a question: Sulfur sticks and ammonia leaks… are you in compliance when using these leak detection devices? In 2014, IIAR updated its edition of ANSI/IIAR 2 – Standard for Safe Design of Closed-Circuit Ammonia Refrigeration Systems, which PROHIBITS their use when charging is being…...

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Bypassing safety critical valves

In almost every PHA I have done since 2000, we find safety critical valves or instrumentation with a built-in bypass around them. I understand the need for a bypass WHEN IT IS FOR MAINTENANCE of the device, but in no sane world do we put a bypass around a safety-critical device so that the process…...

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OSHA issues PSM citations at ink and coatings manufacturing facility (Flammable Liquids & $183K)

The operators of a global ink and coatings manufacturing company could have prevented an employee from suffering burn injuries from a flash fire that erupted in an industrial mixing vessel containing flammable liquids and vapors by following federal regulations for handling of highly hazardous chemicals. An OSHA investigation determined a flash fire sparked in the…...

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When you see it… (Bollards)

How many code/RAGAGEP violations can you identify? Tip: Code(s) and RAGAGEPs require equipment to be protected against contact with mobile equipment when that contact could lead to an LOPC event involving a hazardous material. Answer(s) below:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Improving Safety at Facilities within the Pacific Northwest with Smaller Ammonia Refrigeration Systems (EPA RMP GDC)

While anhydrous ammonia has many environmental and operational benefits, it is also an extremely hazardous substance that, if accidentally released, presents a significant health hazard because it is corrosive to the skin, eyes, and lungs. Ammonia is also flammable at certain concentrations in air. The Environmental Protection Agency (EPA) would like to work with facilities…...

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Pneumatic Pressure Testing gone bad (Wrong Hose used for N2)

During a recent offshore inspection, a BSEE inspector observed operator personnel installing a 100-foot high-pressure hose, with a Maximum Working Pressure (MWP) of 5000 psi, to test pressure safety valves on pipeline pumps. The hose used was designed for hydraulic fluid and not suitable for high-pressure nitrogen; when nitrogen gas at 2500 psi was injected…...

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