Chemical Process Safety (PSM/RMP)

Hierarchy of Hazard Control Analysis (HCA)

Following the August 2012 fire and chemical release at a San Fransico Bay Area refinery, the Governor of CA formed the Interagency Working Group on Refinery Safety to examine ways to improve public and worker safety through enhanced oversight of refineries, and to strengthen emergency preparedness in anticipation of any future incident. The Interagency Working…...

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Hot Work Incidents Involving NH3 Refrigeration Facilities (NFPA Data 2011)

With the recent Hot Work fire in KS at a beef processing plant, I was looking for my posting regarding the 2011 NFPA Loss Report(s) for refrigeration facilities and realized it had not made the move over to the new website.  So here it is again.  Some really good loss data in here(albeit it is…...

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NFPA 77 and the use of jumper cables and star washers at flanges

One of, if not the most critical, aspect of flammable liquids/gases piping is the bonding and grounding of the piping. And unfortunately, this “safety system” is often neglected and not managed as a PREVENTION LAYER of protection. It’s not like we don’t have good guidance in this need; NFPA 77: Recommended Practice on Static Electricity…...

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There is a BIG difference between a Compressed Gas and a Liquified Pressurized Gas (and it matters immensely!)

It has been a while since we have mentioned/discussed the refrigerant HFO-1234yf – which has taken the car manufacturer’s on a ride down the PSM lane of H_LL!  I have had several discussions with these businesses and for the life of me, I am puzzled as to where this idea that NFPA 55: Compressed Gases…...

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NFPA 58 (the leading Flammable Gas code) updated to 2020 Edition

With the absence of an OSHA Flammable Gas standard I have been using NFPA 58 since 1994 and it is one of my all time favorite RAGAGEPs.  I am always pushing clients to use it for their flammable gases, as well as the IFC Chapter 58, especially when their flammable gases are stored/processes/handled as a…...

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Piping inspections during installation (API 570)

I recently received a question from a client about “piping inspection methods for newly installed piping”. It seems that a general contractor was advising the facility that they were “required” to do some “thickness testing” on newly installed piping as part of the installation QA/QC. The PSE asked me “So are we required to take…...

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PSM and Aerosol (Flammable Gas) Containers Stored in Warehouses/Distribution Centers

This is an EXCELLENT LOI from OSHA that covers three (3) IMPORTANT aspect of PSM applicability: Co-Location of smaller containers of flammables that could be impacted by a single event (i.e. fire) Once a process is PSM covered it remains such UNTIL such time the employer puts in place a means to LIMIT the quantity of the…...

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Why some refrigerant piping falls into ASME B31.3 rather than B31.5

The car manufacturers have begun using a new refrigerant for our cars and trucks air conditioning systems.  This new refrigerant, HFO-1234yf, is received by truck, stored as a liquified (pressurized) gas, and dispensed into the vehicles A/C unit.  The piping associated with this storage and transfer of this refrigerant must meet…… Membership Required You must...

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Is a CUI inspection required for insulated vessels?

We see a lot about Corrosion Under Insulation (CUI) as it relates to piping, but we can not forget that the same failure mode can occur on vessels as well.  API 510 spells out some ranges as to when we MUST consider the need for a CUI inspection on our vessel(s)…. Membership Required You must...

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API 510 Internal Inspection Frequency

Sorry for a lack of posts these last couple of weeks, they have been crazy with travel and work.  But I wanted to follow-up on a lot of questions and comments I got regarding my “Internal inspections… of my pressure vessel??? We don’t need no internal inspections” post a few weeks back.  If your engineers/management…...

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EPA’s RMP Vulnerable zone determination

One way EPA selects facilities to be inspected is by “Vulnerable Zones”.  These are areas that could be affected by a release from a chemical accident at a facility subject to the risk management program requirements in 40 CFR Part 68.  So how can a facility determine if they are one of the many facilities that impact a “vulnerable zone” and…...

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