Respondent operates a granular monoammonium phosphate (GMAP) process and a diammonium phosphate (DAP) process at the Facility, meeting the definition of “process” as defined by 40 C.F.R. § 68.3. A different Respondent operates an anhydrous ammonia process at the Facility, meeting the definition of “process” as defined by 40 C.F.R. § 68.3. The GMAP and…...
EPA issues RMP citations @ fertilizer (NH3 & $297K w/ 2 SEPs) Read More »
I am teaching my 3-Day Intermediate Process Safety course this week, and one of the popular exercises we do on Day 1 is the “Vehicle Safety Challenge.” It is designed to teach students to begin thinking about Layers of Protection within the PREVENT-PROTECT-MITIGATE model. Five students in four (4) groups have 15 minutes to… Membership Required...
Prevent – Protect -Mitigation Training Exercise Read More »
The good old “safety incentive program” has been around since man walked upright and has been misleading management since its conception. The concept is valid, based on the old “carrot and the stick” model. There has always been one fatal flaw in these programs… they usually incentivize the WRONG things! The traditional safety incentive programs,…...
Guiding Principles for a Safety Incentive Programs Read More »
One of the top questions we get regarding contractor safety is, “Do I have to evaluate, orientate, and audit subcontractors working for a contractor we hired?”. OSHA’s latest revision of their PSM CPL answered this question. Is the host employer of a PSM-covered facility responsible for the safety of subcontractors?… Membership Required You must be...
OSHA clarifies that sub-contractors fall under 1910.119(h) Read More »
Responding to a report of workers being exposed to anhydrous ammonia, federal investigators found a Madison ice cream plant lacked sufficient process safety management procedures to control the release of hazardous chemicals. Investigators with the U.S. Department of Labor’s Occupational Safety and Health Administration determined the Ice Cream facility failed to document that equipment was…...
OSHA issues PSM citations @ ice cream plant (NH3 & $145K) Read More »
On December 14, 2023, OSHA published its revised Compliance Directive for Process Safety Management standard 1910.119, effective January 26, 2024. This new version is in Q7A format and was done nicely, although there are a number of things in the answers that I am sure will be challenged. I have highlighted some of the interesting…...
OSHA updates its PSM CPL (CPL 02-01-065) – Part 1 Application Read More »
HOP is NOT an Element of a Safety Management System (SMS) HOP principles are HOW we manage our SMS We see a lot of discussions on social media regarding the role of HOP and Psychological Safety, two methods I fully embrace should be used in OSH and PSM. However, I view these two methods…...
Something to think about… HOP is HOW we manage our SMS Read More »
Let’s talk about DE-incentivising businesses to properly manage Occupational Safety and Health (OSH), even at the most basic level. OSHA now requires businesses to report their injury and illness logs, which they will use to identify workplaces needing a compliance inspection. They are doing this due to their lack of adequate resources, and they want…...
Sweating the “small stuff” matters in process safety management. Meeting the details of our chosen RAGAGEPs matters! Although I am often told, “That is a picky audit finding,” it is what it is. Far too many facilities believe that designing their process piping to be bolted flange assembly vs. welded joints is somehow easier; in…...
ASME PCC-1 TIGHTENING PROCEDURE – Pressure Boundary Bolted Flange Joint Assembly Read More »
We have discussed the critical role of “torque” in constructing our chemical processes. I catch a lot of flack for my insistence on this critical function, for which I am genuinely surprised. But our piping design and construction RAGAGEP (ASME B31.3) is pretty clear on the matter, and now OSHA and EPA have “caught on”…...
Flanged piping… Torque matters (at least it does to OSHA) Read More »
The refrigerant in this accident is R-32 (Difluoromethane), described as ” a colorless, odorless, mildly flammable gas. “Its ASHRAE rating is A2L, making it a CAT1B flammable gas if OSHA adopts Rev. 7 of the GHS this year. These A2L “mildly flammable gases” are exempt from many of the requirements other flammable gases must meet…...
R-32 is one of those “mildly flammable gases” (A2L) Read More »
Another pressuring test “gone bad”. I want to remind anyone who wonders how to DEFINE and QUANTIFY a “safe distance” when piping is being pressure tested, especially when that test is a “pneumatic” test. ASME PCC-2–2022, Repair of Pressure Equipment and Piping, Mandatory Appendix, 501-III, Safe Distance Calculations for Pneumatic Pressure Test is an EXCELLENT resource to…...
Catastrophic and FATAL failure of 12″ (25′ long) pipe during pressure test Read More »
