Much like it is in process safety, the Management of Change (MOC) tool may be the most despised element of an SMS. However, a recent safety assessment with a local client identified the lack of performing an MOC on significant changes to production machinery and rates. The facility is NOT a PSM facility, but they […]
The words “audits” and “inspections” often get used as if they are the same thing – THEY ARE NOT the same. I always like to say we inspect “things,” and we audit those inspections. Much like my previous post earlier this month, explaining the difference between “examinations” and “inspections” as used in ASME B31 series;
One of the more critical elements of an SMS is “auditing.” In the Plan-Do-Check-Act model, auditing falls within the “CHECK” function. I like to say it’s the element that keeps us honest and informed. And with that in mind, I break down my audits into three (3) layers: → 1st Party → 2nd Party →
In the old days, the secondary containment around flammable liquid storage tanks could be a single system in which all the storage tanks sat. Today, that is NOT the case. Both NPFA 30 and IFC Chapter 57 require secondary containment to be designed so that an LOPC from one tank cannot affect the other tanks
If your team is focused on an event’s probability or likelihood, you’re NOT doing SIF! The Serious Injuries and Fatalities (SIF) model is intended to IDENTIFY events that have opportunities to cause life-altering injuries and death. And yes, most of these will (hopefully) have LOW frequencies/probabilities. So, to justify NOT responding to these LOW frequency
The purpose of barrier[/controls/safeguards] management is to make the kind of implicit controls explicit: to be clear about exactly what controls are relied on to prevent incidents, to understand their characteristics, to have an understanding of how reliable they can be expected to be, and to know what needs to be done to ensure the
Eight people, including five (5) contract workers and three (3) fire service personnel, were admitted to the hospital after they inhaled chlorine gas following a leakage at a water treatment plant.
Respondent operated a facility (the “Facility”) to manufacture chlorine, bleach, and hydrochloric acid. Respondent produced, used, or stored more than 2,500 pounds of chlorine at the Facility and was subject to the requirements of CAA § 112(r)(7). Respondent produced, used, or stored hydrogen at the Facility and was subject to the requirements of CAA §
In terms of Fire and Building Codes, we have five (5) recognized areas associated with handling hazardous materials. We refer to these high-hazard areas/occupancies as “Group H”. High-hazard Group H occupancy includes, among others, the use of a building or structure, or a portion thereof, that involves the manufacturing, processing, generation or storage of materials
During a recent design review, we encountered some questionable “normal breathing” designs. I have always used the simplest of tests to ensure the tank has ADEQUATE venting during filling and emptying. Although OSHA allows the designer to use API 2000 (1968) or “other accepted standards,” the simplest test is that the VENTING capability MUST be
“We were doing some cleaning at the end of yesterday. I boiled some water in the HLT to pump through the heat exchanger. At the end of the day, there were 40-50 gal left in our 3bbl HLT. I turned off the heat and went home for the night. The next morning, I came into
An ISO container, partly filled with Monoethylene Glycol (MEG), imploded on the back deck of a ship, spilling around two cubic meters (528 gallons) of MEG onto the deck and to sea and causing unrepairable damage to the tank itself. There were no injuries. The tank was a 26-cubic-meter tank containing ten cubic meters (6600
