Chemical Process Safety (PSM/RMP)

EPA issued a letter explaining what incident investigations and root cause Analysis requirement changed from the proposed to final rule and what the final rule requires with regards to incident investigations.  Here’s what EPA said:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

“Safer Technology And Alternatives” (STAA) refer to risk reduction strategies developed using a hierarchy of controls that are considered inherent, passive, active, and procedural. This strategy can be applied initially to all design phases and then continuously throughout a process’s life cycle. STAA includes concepts known as inherently safer technologies (IST) or inherently safer design…...

EPA has issued two letters that better clarify what the “Third Party Audit” requirements changed from the proposed to final rule and what the third-party audit requirements actually are.  Here’s what EPA said:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

EPA has established the following dates for facility owners and operators to comply with the revised rule requirements:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

EPA issues “letters” on their website that helps clarify many of their rule requirements, much like OSHA’s Letters of Interpretation.  This week OSHA issued twenty-one (21) such letters following their FINAL amendments to their Risk Management Plan rule.  These two (2) letters address what EPA has done to further the safe storage and handling of Ammonium…...

OSHA cited a refinery in 2008 for failing to inspect a piece of equipment known as the positive pressurization unit (PPU). The refinery contends that this citation is unlawful because the PPU is not encompassed by the relevant regulations. Because this dispute involves the interpretation of a binding regulation promulgated by the agency, we defer…...

Delek purchased an oil refinery located in Tyler, Texas from Crown Central and took possession on April 29, 2005. Beginning in February 2008, OSHA conducted a four-month inspection of the refinery and issued a citation on August 18, 2008, finding violations of 29 C.F.R. § 1910.119 and other regulations that are not at issue here…....

Safeguarding is the provision of protective measures to minimize the risk of accidental damage to the piping or the harmful consequences of possible piping failure.  In most instances, the safeguarding inherent in the facility (the piping, the plant layout, and its operating practices) is sufficient without the need for additional safeguarding.  In some instances, however,…...

Three distinct elements of a flanged joint must act together to provide a leak-free joint: the flanges, the gasket, and the bolting Factors that affect performance include the following:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

The revisions to 2015 IFC, Section 606.12 clarify the code requirements and add references to two (2) International Institute of Ammonia Refrigeration (IIAR) standards and one American Society of Heating, Refrigerating and Air-Conditioning Engineers, Inc. (ASHRAE) standard for design and operation of ammonia refrigeration systems.  This edition of the IFC also pulls in a lot…...

In an effort to provide you with the new language I have presented this material, cut from EPA’s early release document which was several hundred pages.  Here is what is actually changing in the rule:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

My good friend and Ammonia Refrigeration PSM extraordinaire, Brian Chapin with RCE, has allowed me to share his work here.  I figured I could not have done any better on this breakdown so I asked if he minded I share this at SAFTENG, we lucked out and he said yes!  This is an excellent breakdown,…...