First, let’s define what this article is all about. Has your facility ever had a leaking flange? Just a tiny drip of liquid or a small release of gas? What is the most common response to this leaky flange? Someone goes out and tightens the flange bolts to stop the leak. This practice is done…...
ASME and Hot Bolting and Half Bolting Procedures Read More »
RMPs MUST be updated at least once EVERY five (5) years. Owners and operators responsible for RMP implementation should review the factsheet A Checklist for Submitting your Risk Management Plan (pdf). This factsheet provides a checklist to consider in updating and resubmitting RMPs. Use EPA’s RMP*eSubmit for your resubmissions. For additional information see the RMP*eSubmit Users’…...
Re-Submitting your RMP Read More »
Under the Clean Air Act, Section 112(r), the EPA established a program requiring facilities possessing greater than certain threshold quantities of 140 chemicals to provide risk management plans to the EPA.1 As part of this reporting requirement, facilities are required to determine the worst-case scenario release from a single chemical process, using EPA criteria and guidelines.2 Facilities…...
RMP Facilities in the United States as of December 2009 Read More »
It cannot be assumed that workers will naturally begin to report problems, errors, and near misses once a just environment is in place. There are a number of organizational as well as psychological barriers that must be hurdled before a reporting culture can be put in place. The first barrier to overcome is… Membership Required...
Establishing a Reporting Culture (Psychological Safety) Read More »
In older facilities, we see illumination for an exit sign coming from an external source. Section 1013.6 of the IBC regulates the graphics, illumination, and emergency power supply for such signs. Although no particular color is specified for exit signs, it is REQUIRED that the color and design of the signs, the lettering, the arrows,…...
Externally vs. Internally illuminated EXIT signs Read More »
Three (3) ingredients are vital for driving the safety engine, all of them the province of top management or what the organizational theorist, Mintzberg, has termed the strategic apex of the system. These driving forces are: commitment, competence and cognizance Reason’s three C’s…. Membership Required You must be a member to access this content.View Membership...
Take any of the following steps below that may be necessary to guard against stored energy(s) left in the equipment after it has been shut down and isolated from its energy source(s)…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
De-enerizing Stored Energies Read More »
An older post, with updates…Ever since the 2005 BP Texas City tragedy, refineries and chemical plants have been working diligently to review “facility siting” risks for their facilities. As with all of the PSM elements, many of us took this new focus as a learning opportunity. We had all done something we called “facility siting”…...
A reverse look at Facility Siting and Change Management Read More »
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…...
