Both OSHA and NFPA state that if the pipe does NOT terminate within the space, the pipe does NOT have to be evacuated to consider the contents of the pipe a “potential” to generate a HAZ ATM. In a recent OSHA LOI, OSHA used several thresholds that the employer should/must use in its evaluation of […]
The transfer of hazardous materials from a cargo-tank motor vehicle to fixed-site storage poses a critical vulnerability in chemical handling. While high-speed highway collisions capture more attention, the Pipeline and Hazardous Materials Safety Administration (PHMSA) estimates that roughly 25% to 50% of serious HAZMAT transportation incidents actually occur during loading and unloading operations. These accidents
When we introduce a pipe welding machine (such as an orbital welder) into the fabrication process, the focus of the certification fundamentally shifts. Under industry codes such as ASME Section IX, the individual operating the equipment is no longer classified as a “Welder”; they are designated as a “Welding Operator.” Because the machine handles the
I am working with a client who is making every effort to comply with the Maximum Allowable Quantity (MAQ) limits for a flammable liquid process area. This process is a PSM-covered process, so I offered up how to work beyond the MAQ of 480 gallons for a fire control area. This compliance option 5001.3 was
It is designed to collect and remove condensate while isolating the relief valve from the mechanical stresses of the discharge piping. Here is a breakdown of its primary functions and operational mechanics:
I grew up in the process industries doing PSM/RMP; however, most of the air receivers at my plants were NOT associated with the PSM/RMP-covered process(es). And yet they were all in our MI program for routine inspections and testing of their PSVs. In fact, every pressure vessel in service on the plant site and its
OSHA has made significant changes to Chapter 4, The VPP Safety and Health Management System. Chapter 4 now requires VPP participants’ SHMS to consist of the seven (7) core elements described in OSHA publication 3885, Recommended Practices for Safety and Health Programs, October 2016, and in OSHA publication 3886, Recommended Practices for Safety and Health
NOTE: If you’re in an INDUSTRIAL facility, especially one with a PSM/RMP-covered process, B31.9 is NOT your piping RAGAGEP! IFC 5703.6.3 dictates that piping for flammable and combustible liquids must be hydrostatically tested to 150% of the maximum anticipated pressure (or pneumatically tested to 110%). However, it offers a carve-out: “Unless tested in accordance with
I get some interesting questions and see some very strange things in my work around the country, but this one seems to have grown legs in the world of “cost-cutting” in safety. “Let’s have our maintenance people do the ‘annual maintenance’ on our fire extinguishers”… um NO WAY! And this is just not a “Haywood
I will be fully upfront for those who wish to challenge me on this topic. YES, ASME B31.3 and 31.5 explicitly state that certain records that are required by the standard do NOT have to be “retained”. However, most people who challenge me on this topic fail to see that ittybitty two-letter word “if” in
Structural collapse caused the release of around 2,400kg of highly flammable liquid petroleum gas.HSE investigation found that long-standing corrosion of the steel tower was not dealt with.Workers exposed to the risk of serious injury and burns in a major incident. The refinery has been fined £1 million after a major gas leak following an investigation
OSHA uses the General Duty Clause (GDC), Section 5(a)(1) of the OSH Act as a “gap filler” to cite employers for recognized chemical hazards when a specific standard (like the Process Safety Management standard, 29 CFR 1910.119) does not technically apply. There are some critical legal limitations on GDC Enforcement: OSHA’s ability to invoke 5(a)(1)
