Retail facilities are exempted from PSM requirements. At first glance, it appears this is a pretty broad exemption, as the standard just states. This section does not apply to:1910.119(a)(2)(i) Retail facilities; But as I wrote about last month, not all retail facilities selling a PSM Highly Hazardous Chemical (HHC) in the USA are exempt. In…...
As we have discussed before, the EPA broke down its RMP rule into three (3) programs, and each program has criteria that will place the process in one of the three. However, the one criterion that confuses some businesses is how EPA used the North American Industry Classification System (NAICS) to qualify a process for…...
EPA’s RMP and Program 3 NAICS #’s Read More »
The proper installation of bonding and grounding systems is important in the protection of personnel and property. At the time of installation, a resistance test is needed to confirm electrical continuity to ground. Evaluating the maintenance requirements, the bonding and grounding system can be divided into three categories:… Membership Required You must be a member...
Testing and Inspection of Bonding/Grounding Systems Read More »
Jan 26, 2006 – An accident occurred in a factory in Brazil during pneumatic pressure testing with air from pipework around a tank. There were no blind flanges placed to isolate the pipework to the tank; only the valves were closed. Probably one or more valves failed or were not closed as the tank underwent…...
Catastrophic Failure during pneumatic pressure test Read More »
In the world of process safety, this is a no-brainer; but in normal manufacturing facilities, the answer can be quite confusing. Bottom line… if your facility has a PSM-covered process (even an RMP Program 2 or 3 process) we are REQUIRED to have an EAP that complies with 1910.38. But when we are not a…...
Am I required to have an Emergency Action Plan? Read More »
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Who at your place of business calls the National Response Center after your business has experienced a chemical incident. Not many people have ever had to call this center (luckily!) but if your business ever does have a “reportable release” a call just like this one MUST BE MADE within 30 minutes after you have…...
UPDATE – Calling the National Response Center Read More »
I could have sworn I had already written about this hazard, but I’m guessing it was inside one of my social media groups. So BUCKLE UP, Butter Cup, as this is going to make a lot of folks unhappy. Question: Do I have to isolate my fixed fire suppression system protecting my PRCS?… Membership Required...
Entry into PRCS’s protected by a fixed fire protection system Read More »
What happens when you try to pull water out of a tank using a 3HP pump and leave the vent closed… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
The power of a vacuum (photo) Read More »
I have posted numerous fatal accidents that occurred during the pressure testing of piping and pressure vessels. Although hydrostatic testing involves less energy release should something fail vs. using pneumatic pressure, the hazard(s) are still HUGE and must be respected. This incident involved a propane bullet built in 1994 and placed into service in 1996,…...
Brittle Fracture (Catastrophic) Failure during HYDROTEST of Propane Bullet Read More »
A 43-year-old assemblyman died on May 26, 1999, from chest injuries he received earlier that day when struck by a high-pressure water jet emitted after the failure of a gasket during a hydrostatic test of a cooling coil for an air-cooled heat exchanger. At the time of the incident, the victim was part of a…...
Hydrostatic test of a cooling coil for an air-cooled heat exchanger fatality (OK-FACE) Read More »
A process, in terms of Process Safety Management, is defined as: “Any activity involving a regulated substance including any use, storage, manufacturing, handling or on-site movement of such substances, or any combination of these activities. For the purposes of this definition, any group of vessels that are interconnected, or separate vessels that are located such that a regulated substance could…...
What is a process? Read More »
