Chemical Process Safety (PSM/RMP)

During stakeholder outreach as part of EO 13650 and during OSHA’s PSM SBREFA (Small Business Regulatory Enforcement Fairness Act), OSHA and EPA received multiple comments from stakeholders expressing confusion on the applicability and overlap between OSHA’s Process Safety Management (PSM) standard and EPA’s Risk Management Plan (RMP) regulation. In the Clean Air Act Amendments of…...

“Minor” LOPC events that are allowed to continue over a weekend can be a COSTLY MISTAKE!  Any LOPC event MUST be reported ASAP to that it can be addressed, regardless of how “minor” it may be considered!  We have to keep our HHC/EHS’s in their PRIMARY CONTAINMENT and when we have a failure that lets…...

Opening a Natural Gas Condensate line with a battery-operated drill inside a compressor building is ASKING for trouble.  Basic HAZLOC work practices include using INTRINSICALLY SAFE tools that are APPROVED for the HAZLOC, which has been an OSHA requirement since 1981… 1910.307(c) Electrical installations. Equipment, wiring methods, and installations of equipment in hazardous (classified) locations…...

At approximately 10:40 a.m. on April 2, 2019, the housing of a three-inch Y-strainer of an isobutylene line that fed into reactor K8 ruptured and isobutylene was released, forming a vapor cloud. Three employees responded to mitigate the isobutylene vapor in the reactor area…. Membership Required You must be a member to access this content.View...

At 4:45 a.m. on July 29, 2018, 16 employees were operating vegetable packaging equipment and performing material handling activities at a vegetable processing facility that used ammonia refrigeration. A fan unit for an evaporative condenser unit fell onto the condenser coil due to the structural failure of a motor bracket. While falling, the fan cut…...

This video is exactly why the ASME B31 piping RAGAGEPs prefer hydrostatic pressure testing vs. pneumatic methods.  When we take piping up to 400 psi and higher we are creating a serious hazard; thus the code(s) have built-in administrative controls to ensure personnel are NOT near the piping when the test pressure is achieved and…...

This is NOT my personal interpretation of this ASME B31.3 “leak testing” requirement(s), but it is the official position of the Alberta Canada pressure equipment safety authority.  I share this as another “official” explanation of what ASME B31.3 requires in terms of pressure/leak testing and this regulatory agency’s interpretation of how they read this critical…...

This little matter always leads to an energetic discussion during our Emergency Response assessments/planning exercises.  But most states have a state code that will read something like this… Access to refrigeration systems having a refrigerant circuit containing more than 220 pounds (100 kg) of Group A1 or 30 pounds (14 kg) of any other group…...