Safety Info Posts

NFPA 51B – 2019 Updates to Fire Watch and Fire Monitoring Requirements

Many of us in the PSM/RMP arena use NFPA 51B as our Hot Work Safety Standard, rather than 1910.252(a) and with that said I thought I should update us on NFPA’s 2019 edition of 51B which includes several key improvements.  Probably the biggest changes from the 2014 edition are: the term FIRE WATCH is now officially…...

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Emergency Pressure Control Systems (EPCS) and Car Seal Program

One phrase that drives me crazy while working with my friends in the Ammonia Refrigeration industry is, “Come on, Bryan; we’re not a refinery or chemical plant; that is unnecessary here.”  For example, recently, we were asked to aid in an investigation into a reportable release from a PSM/RMP-covered process, and during our review of…...

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OK is just NOT good enough in Safety

We all know we, as safety professionals, see life through a different lens than most others.  But ever since I started seeing these AT&T commercials “Ok is just not good enough” I always go back to my HAZMAT ER days.  One of the last ER’s I was called upon for assistance, I was delegated to a…...

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EPA RMP citations @ food plant (NH3 & $34K)

Respondent operates an ammonia refrigeration plant and has on-site for use, 130,000 pounds of ammonia for cold food storage. Respondent has submitted and registered an RMPlan to the EPA for its stationary source and has developed an RMProgram accidental release prevention program for the stationary source’s single RMProgram level 3 covered process. On November 8,…...

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The magic of Carbon Monoxide… Chemical Asphyxiant (Video)

You are the entry supervisor for entry into a Carbon Monoxide (CO) Tank.  Your meter is equipped with an Oxygen Sensor, but it does NOT have a CO sensor.  You proceed with your atmospheric testing, as you were told years ago that as long as the Oxygen was over 19.5% that all will be OK. …...

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Today could have been hell… what are we starring at?

We have an uncontrolled release from our PSM/RMP covered process today, February 5, 2019.  We have trained for this day.  We have inspected our gear, well most of it, each month for years.  We don our LEVEL A suits, which have been pressure tested annually and cared for per every single manufacturer’s requirements.  Under our LEVEL…...

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EPA’s RMP and Ammonia Refrigeration

UPDATED on 2/6/19, based on feedback from my friend and Refrigeration PSM Extrodinare Brian Chapin over at RCE (A former Partner in Safety).  I have shared his analysis and my rebuttal/agreement… By a long shot, these are the top three (3) issues found with Ammonia Refrigeration RMPs: The NH3 is “Liquified by Pressure” – not…...

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OSHA Inspections: Regional Emphasis Program on Ammonium Nitrate

This 10-minute video provides an overview of the OSHA inspection process under the agency’s Regional Emphasis Program for Fertilizer Grade Ammonium Nitrate and Agricultural Ammonia Facilities.  … Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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LOPC… just four letters but they mean SO MUCH to process safety engineers

One of my favorite parts of teaching the 1-day PSM Intro course at ASSE SeminarFest is the vast numbers of students and all of their learnings and experiences being shared. This year was even better than years before – in fact, we had so many side-bar discussions because of the great input from the students…...

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An emergency alarm system at a PSM/RMP facility and NFPA 72

Those in the PSM/RMP world know that the facility is REQUIRED to have an Emergency Action Plan (1910.38) and by virtue of having to comply with 1910.38, we also have to comply with 1910.165 Employee Alarm System. The language in 1910.165 is really vague and causes much confusion when it comes to the emergency alarm…...

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Why is a medical evaluation necessary for those wearing a respirator?

Breathing… we do it all day long, every day, and yet we never even put a thought to it.  But so many respirator users do not understand the basics of how we get the air (more importantly, the oxygen in the air) into our lungs so that it can enter our bloodstream for survival.  As…...

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