For those of you that follow my ramblings have heard me rant on about ASME A13.1 and how pipe labeling begins LONG BEFORE a process becomes a PSM/RMP covered process. ALL Hazardous Materials piping has to be labeled! And yes I am well aware of OSHA’s position on pipe labeling and their Globally Harmonized System […]
On March 25, 2008, the State of New Jersey adopted rules requiring facilities regulated under the Toxic Catastrophe Prevention Act (TCPA) Program, which is PSM/RMP to those of us outside of the state of New Jersey, to perform Inherently Safer Technology (IST) reviews. Both OSHA and Federal EPA have tried to incorporate the IST model
Brian Chapin, Compliance Services Manager NOTE: This article is by my good friend and colleague Brian Chapin @ RC&E in Forth Worth, TX. In full disclosure, RC&E has been a corporate member for several years. Brian was gracious in allowing me to post his work directly at SAFTENG as some of you were having issues
On June 29, 2005, an operator was involved in the following maintenance activities in the Chloropyridines Complex at the employer’s chemical manufacturing facility. He was returning a reactor vessel to service and WAS ATTEMPTING TO DO A PRESSURE AND LEAK TEST USING CHLORINE GAS. The pipeline was supposed to be pressure tested with nitrogen gas
On March 13, 2007, Employee #1, a subcontractor, performed maintenance on commercial foodservice equipment. He was in the kitchen area of a single-story restaurant, attempting to locate the source of a refrigerant leak in an ice cream storage dipping cabinet. Employee #1 connected a Nitrogen cylinder to the dipping cabinet’s refrigeration system via a hose
A refrigeration system was being installed in a new wing of an ice cream plant in 1984. A leak test was being performed by employee #1 on a “low-pressure tank” which was filled with a mixture of ammonia and air under a pressure of 150 psi. As he squirted a soap bubble solution onto a
At 11:30 a.m. on September 04, 2018, a group of employees was working on a beef processing station. Employee #1 was REPLACING A DEFECTIVE AMMONIA PRESSURE GAUGE FOR A HOT-GAS AMMONIA LINE when he broke off the gauge and associated valve, releasing ammonia into the area and cut/fab floor below. The plant was evacuated and
The U.S. District Court for the Southern District of New York has approved a consent decree between the U.S. Environmental Protection Agency and the Environmental Justice Health Alliance for Chemical Policy Reform, Clean Water Action, and Natural Resources Defense Council. The consent decree requires EPA to issue long-overdue rules requiring robust hazardous substance spill-prevention and
Many years ago I had an open debate with a “grandfather of refrigeration” on his turf in front of about 30 other refrigeration professionals and the debate was about “flange connections”, ASME B16, and TORQUE and how it all applied to covered processes regardless of what the HHC/EHS was, including anhydrous ammonia in a refrigeration
My January article “What does a “suitable telltale indicator” look like when we have a dual relief system” was a hit as I received numerous requests for information on how to get these special gauges. As I promised each of you in the ammonia refrigeration industry, here is what I have used on my NH3
On December 30, 2019, the Bureau of Safety and Environmental Enforcement (BSEE) Inspectors working offshore discovered that a level safety high had been improperly deactivated with a zip tie, resulting in the issuance of a P-103 incident of noncompliance (INC). There have been multiple instances across the Gulf of Mexico in which operators have failed
Although this Coast Gaurd Bulletin is specific to maritime vessels, it can and should be applied to relief valves on land as well. There are some really good practices in this bulletin, such as when to perform the test in-situ vs. bench testing. The incident happened when a relief valve on the associated compressor was
