Safety Info Posts

Failing to CLOSE a PRCS Entry Permit properly can have Process Safety implications months after the entry

As most of you know, PRCS Entry is one of the specific SWPs called out in the PSM and RMP standards. But many programs fail to meet 1910.146(f)(4), and a recent CSB accident report tied the requirement for canceling a permit to a catastrophic explosion event. 1910.119(f)(4) The employer shall develop and implement safe work

The 15-Year Service Life Debate for Composite Cylinders (SP 16320)

The most significant friction point involves PHMSA and SCBA Fully Wrapped Carbon-Fiber Reinforced (CFFC) aluminum-lined cylinders on Special Permit 16320 and the use of Modal Acoustic Emission (MAE) testing to extend the life of composite cylinders. Fully Wrapped Carbon-Fiber Reinforced (CFFC) aluminum-lined cylinders have a 15-year service life. PHMSA has investigated and granted limited special

Pipeline Safety & Potential Impact Radius (PIR) Re-evaluations

NTSB’s historical investigations into major gas and hazardous liquid pipeline ruptures continue to shape current rulemaking tracking. PHMSA has been actively reviewing the established Potential Impact Radius (PIR) calculation methodologies used in integrity management programs. The review aims to determine whether current mathematical models accurately account for human response data, rapid-ignition variables, and modern accident

FRC must be the outer layer – NYLON Hi-Vis vest are a problem

In today’s workplaces, it’s hard to find a large business that does not require Hi-Vis Vest/Workwear. What is not hard to find is a business with HAZLOCs where workers are required to wear FRC but are wearing nylon Hi-Vis vests OVER their FRC. I am all for making workers more visible to powered industrial trucks

How often do SCBA cylinders need to be “topped off” to ensure they stay above 90% full?

The amount of breathing air consumed during a monthly SCBA functional test (often referred to as the “monthly inspection” or “flow test”) varies slightly by manufacturer and the specific depth of your inspection/testing SOP. However, for a standard 30-minute/45-cubic-foot cylinder, you can estimate the usage based on the required NFPA 1852 checks.

When you see it… Flange Jumpers for Flammable Liquid & Combustible Dusts Piping

Many may be familiar with “flange jumpers,” or some may call them “bonding jumpers,” that are used to ensure a continuity to ground across a flange with gaskets that act as “insulators”, such as PTFE gaskets. During a recent walkdown of a flammable liquids process, I came across this “jumper”. Design called for “jumpers” on

EPA RMP/EPCRA citations @ Refinery (HF & $270K)

Respondent operated a facility (the “Facility”) that refines petroleum products using a hydrofluoric acid alkylation process. On June 2-3, 2022, EPA performed an inspection of the Facility to evaluate compliance with the Comprehensive Environmental Response, Compensation and Liability Act (“CERCLA”) Section 103, EPCRA Sections 304-312, and CAA Section 112(r). Based upon the information gathered during

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