Chemical Process Safety (PSM/RMP)

Hazardous Locations: When, Where, and How

When most ordinary people hear the term “Hazardous Location” many conjure images of a dangerous location associated with typical hazards; however, when a safety engineer or engineer from the process industries hear the phrase we immediately elvate our antenna and sit up and pay close attention to what is being said.  But for those outside…...

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Does ASME B31.1 require pressure/leak testing on PSV vent piping to atmopshere?

The requirement for pressure and leak testing on PSV vent piping depends entirely on whether the piping is classified as Boiler External Piping (BEP) or Non-Boiler External Piping (NBEP). If the vent line is part of the BEP (directly attached to the boiler safety valves under the jurisdiction of ASME Section I), the testing requirements…...

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Process Safety and Engineered Pressure Enclosures

I can still remember the day I was told: “the pipe failed its thickness testing – but don’t worry we are going to use a pipe clamp so we can keep using it”.  I had just attended my API 570 and 510 courses to learn all about process equipment inspection protocols.  Not once did I…...

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Canada’s Ammonia Refrigeration staffing requirements (Public Occupancies)

Canada has an interesting requirement for their NH3 refrigeration plants that operate within structures where the general public could be exposed to the NH3.  Since the promulgation of OSHA’s PSM standards in 1992, OSHA has shied away from even mentioning “staffing” for a covered process.  In the USA, we have plants that run 24/7/365 without…...

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Line Break gone BAD (Chlorine)

We have yet another failure of enormous proportions.  When two workers, one of which is a Supervisor, are opening a liquid chlorine line and they have on supplied-air respirators without the regulator attached to the facepiece we have entered into the Twilight Zone.   WorksafeBC has levied a $318,707 fine against the city’s water-treatment plant for:…...

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When we fail @ Hot Work Safety (Video of Designated HW area)

Whether we’re in process safety or just good ole fashioned occupational safety and health, the act of performing hot work (welding to the layperson – my feeble attempt at some Dumb and Dumber humor) can be one of the most dangerous task workers can perform.  Add in the fact the hot work is done within…...

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CSB’s Accidental Release Reporting

Here is an initial look at the rule, signed by the CSB Interim Executive today. The final rule requires an owner or operator of a stationary source to submit an accidental release report to the CSB. The rule describes when to file a report of an accidental release and the required content of such a…...

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No Procedure for Requesting RMP Five-Year Review Extension

The Risk Management Program (RMP) regulations require the owner or operator of a stationary source to revise and update the source’s RMP at least once every five years from the date of its initial submission or most recent full update (§68.190(b)).  Is there a procedure for obtaining an extension to complete the five-year review? … Membership...

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Types of Information Relevant for Response Planning

The Risk Management Program emergency response coordination activities require the owner and operator of a stationary source to provide to the local emergency planning and response organizations: the stationary source’s emergency response plan if one exists; emergency action plan; updated emergency contact information; and any other information that local emergency planning and response organizations identify…...

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Time Frame to Submit RMP Emergency Contact Information Changes

How much time does the owner or operator of a stationary source have to submit a correction to a Risk Management Plan when the emergency contact information changes? The Risk Management Plan (RMP) regulations require an owner or operator of a stationary source to correct their RMP within one month (i.e., 30 days) of any…...

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Key Safety Measures for Ammonia Refrigeration Processes (EPA & IIAR)

The following is a list of key safety measures developed by EPA in coordination with the International Institute of Ammonia Refrigeration (IIAR). They are measures that EPA and IIAR agree are required elements for ammonia refrigeration facilities (regardless of an ammonia refrigeration system’s age or size) for the system to meet the requirements of 40…...

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What does a “suitable telltale indicator” look like when we have a dual relief system

First I want to thank my Pittsburg friends for another great visit and for being my “think-tank” of world-class engineers and chemists.  I always leave smarter and happier after my time with these folks.  And with all my visits I always come away with great real-world examples of how process safety is supposed to be…...

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