Hazardous Materials

Can OSHA issue 5(a)(1) citations when a process is under its PSM TQ?

Apparently, they can and have. Here are some GDC citations for an NH3 refrigeration process. These were part of a large release inspection that included some HAZWOPER and HAZCOM citations. My only guess is that these GDC citations are tied directly to the NH3 release, but I have not yet seen the field notes, so […]

What is a Hierarchy of Controls Analysis (HCA)?

A Hierarchy of Controls Analysis (HCA) is a highly structured risk-mitigation methodology. It is specifically required under CalARP Program 4, which applies to petroleum refineries operating within California. While a standard Process Hazard Analysis (PHA) identifies risks and lists existing safeguards, an HCA forces a facility to systematically evaluate whether hazards can be eliminated or

If my flammable liquid storage tanks are equalized together, must my secondary containment account for this?

When flammable liquid tanks are equalized — meaning they are interconnected by piping that allows fluid levels to equalize between them — we MUST account for this in our secondary containment design. From a regulatory and engineering standpoint, the governing principle is to protect against the worst-case single-event release. If tanks are interconnected, a failure

What should a welding QA program include for those visually inspecting the welds?

ASME Section V, Article 9 places the responsibility for the designation and qualification of these individuals on the organization (the employer or manufacturer). The organization is responsible for assigning “qualified personnel” to perform visual examinations. ASME Section V requires that personnel be qualified and certified in accordance with a program established by their employer. The

Fail-Safe Engineered System?

Under certain conditions, the IFC allows “Fail-Safe Engineered Systems” in lieu of “emergency backup power” for safety-critical systems such as ventilation, treatment, or temperature control systems. The code states: 5004.7.2 Fail-safe engineered systems. Standby power for mechanical ventilation, treatment systems and temperature control systems shall not be required where an approved fail-safe engineered system is

CISA and Partners Urge Hardening Automatic Tank Gauge Systems

The Cybersecurity and Infrastructure Security Agency (CISA), the Federal Bureau of Investigation (FBI), the National Security Agency (NSA), the Department of Energy (DOE), the Environmental Protection Agency (EPA), the Transportation Security Administration (TSA), the Department of Transportation (DOT), and the U.S. Department of Agriculture (USDA)—hereafter referred to as “the authoring organizations”—are aware of malicious cyber

N.C. Department of Agriculture and Consumer Services issues a stop-sale order on “Ignik TapRack 4” brand Refillable Propane System

The N.C. Department of Agriculture and Consumer Services has issued a stop-sale order for the Ignik TapRack 4 Refillable Propane System. This device failed to meet several safety standards enforced by the department’s Standards Division. Manufacturers and distributors will have six months to remove these products from retail locations. Online sales shall include a note

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