As we have discussed here many times, our piping is our “primary containment” that seems to be where the vast majority of Loss of Primary Containment (LOPC) events occur. Many reasons for this, which we have spelled out in other postings, but none the less the vast majority of “leaks” occur in our piping. One…...
PSM and RMP (e.g HAZMAT) Pipe Supports… how many and how far? Read More »
March 31, 2009 MEMORANDUM FOR: REGIONAL ADMINISTRATORS THROUGH: DONALD G. SHALHOUB DEPUTY ASSISTANT SECRETARY FROM: RICHARD E. FAIRFAX, DIRECTOR DIRECTORATE OF ENFORCEMENT PROGRAMS SUBJECT: Management of Organizational Change This memorandum addresses the application of 29 CFR 1910.119 (l), Process Safety Management (PSM) – Management of Change (MOC), to…...
Management of Organizational Change (OSHA Letter to RAs) Read More »
EPA can improve its program management and oversight to better assure that facilities covered by the Clean Air Act’s Risk Management Program submit or re-submit an RMP. EPA had not established national procedures for identifying covered facilities that had not submitted RMPs. For the 5 States reviewed, we identified 48 facilities in 3 States that…...
This article is for ANYONE with anhydrous ammonia, regardless if you have 100 pounds or 100,000 pounds of ammonia and your primary means of containment is Carbon Steel. I have written numerous times about the Stress Corrosion Cracking (SCC) failure mode and shared numerous accidents and alerts regarding this failure mode. In this article, I…...
MAJOR CHEMICAL DISASTERS IN INDIA Origin of accident Year Date Location Products involved Number of Deaths Injured Evacuated Explosion (warehouse) 1992 29.04 New Delhi Chemicals 43 20 Fire at a chemical store 1994 13.11 New Delhi Toxiccloud (chemicals) 500 Leakage 1984 03.12 Bhopal* Methyl isocyanate 2800 50,000 200,000 Leakage 1989 05.05…...
MAJOR CHEMICAL DISASTERS IN INDIA Read More »
OSHA’s standards for general industry and the construction industry on hazardous waste operations and emergency response (29 CFR 1910.120 or 29 CFR 1926.65) cover all employees involved in: Clean-up operations of hazardous substances at uncontrolled hazardous waste sites required by Federal, state, local or other governments; Corrective actions involving clean-up procedures at sites covered by…...
Understanding OSHA’s HAZWOPER standard for Emergency Response Read More »
Despite their differences in tradition, emphasis, and application domains, there is no reason why these various models and their associated practices should not coexist harmoniously within the same organization so long as the strengths and weaknesses of each approach are recognized…. Membership Required You must be a member to access this content.View Membership LevelsAlready a...
Three Approaches to Safety Management (Reason, 1997) Read More »
History has shown that flammable vapor ignitions in a number of cases have been proven to reside in mobile equipment working in or around a facility. “Industrial Loader and Forklift Fires,” an NFPA report published in January 2009, states that between 2003 and 2006, an average of 1,340 fires were ignited by heat or ignition…...
Based on eight (8) recent enforcement investigations, conducted by the U.S. Department of Transportation, Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Hazardous Materials Enforcement (OHME), this letter is intended to notify the industry of serious safety problems and non-compliance issues regarding the maintenance, filling, transport and use of nurse tanks in anhydrous…...
Nurse Tank Safety and Compliance Advisory letter (2008 Reminder) Read More »
Twelve days before the Holidays, My Safety Team said to me, No cuts or lacerations Wear your PPE, No slips, trips or falls Watch where you put your feet, No strains, aches or pains Use your safe lifting techniques, Watch your head and keep it safe Always be aware of overhead…...
Don’t Let Safety Take a Holiday! (Poem) Read More »
This article discusses how a facility would need to get one of its coded pressure vessels repaired, altered, or re-rated. The article will cover pertinent code and jurisdiction requirements and the differences among the American Society of Mechanical Engineers (ASME) Code, the National Board Inspection Code (NBC), and American Petroleum Institute (API) requirements, as well…...
National Board Inspection Code vs. API 510 Read More »
A Process Hazard(s) Analysis is a thorough, orderly, and systematic approach for identifying, evaluating, and controlling the hazards of processes involving highly hazardous chemicals. The facility shall perform a process hazard analysis on all processes covered by EPA’s RMP rule and/or OSHA’s PSM standard. The process hazard analysis methodology selected must be appropriate to the…...
Process Hazards Analysis Techniques (Methodolgies, Resources, and Time) Read More »
