Safety Info Posts

No MOC for reduction of inventory to below PSM/RMP TQ leads to LPOC event (engineering out excess flow valves)

A number of years ago a former client decided that process safety was not worth the effort and wanted to get their process below the 10,000 pounds TQ for their LPG.  They hired a local architect/engineering firm that had no experience with the storage, handling, and processing of LPGs.  This “architect/engineering firm” advised the facility […]

Double Block and Bleed – OSHA vs API

The only OSHA standards that make mention of the phrase “Double Block and Bleed” (DB&B) are its Permit-Required Confined Space (PRCS) standards. In both 1910.146(b) and 1926.1203, OSHA defines a DB&B as: the closure of a line, duct, or pipe by closing and locking or tagging two in-line valves and by opening and locking or

A look at back at fire safety

It seems every generation is destined to have its own structure fire tragedy; ours being the Station Nightclub fire in West Warwick, Rhode Island in 2003.  In less than 30 minutes, 100 people lost their lives that night (February 20, 2003).  I had just started consulting and I can remember it well as almost all

Contractor Safety training at petroleum refining or petrochemical manufacturing facilities (WA-OSHA)

The department is initiating rulemaking to implement the advanced safety training requirements for High Hazard Facilities. Chapter 49.80 RCW, enacted in 2019, requires owners of petroleum refining or petrochemical manufacturing facilities to use a skilled and trained workforce when contracting for construction, alteration, demolition, installation, repair, or maintenance work. By January 1, 2022, all workers

Could OSHA issue REPEAT Citations against a “Franchisee” based on an accident at a different franchise?

In November 2019 a manager, 32, of a restaurant, a national chain, was overcome by chlorine gas and died.  The investigation established that a worker at the restaurant spilled a “cleaner” on the floor during the day. Then later that night, a different employee started to clean the floor with a “floor cleaner”. The mixture

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