You know businesses are cutting costs when I get this question.  But it is a good question as we have come across “reclaimed piping” being used in a lesser-degree hazard (e.g., flammable gas to flammable liquid) process.  I personally never experienced this practice in my time in industry, but it has become more popular as businesses look for more ways to reduce costs.  So...

If you have followed me for years, you know I love to use the International Fire Code over outdated OSHA standards.  For me, it is ALL about safety and not compliance; luckily, I have many clients who take the same approach, and we have made some serious improvements to a hazardous process.  Here is a lock at what the IFC states about Bulk Transfer and Process Transfer Operations (5706.5). I...

Employers are required by 29 CFR* § 1910.147(c)(6) to conduct a periodic inspection of written hazardous energy control (lockout/tagout) procedures.  The inspection must be performed at least once annually [per 12-month interval, as stated in 1910.147(c)(6)(i)] because of the significant risks associated with inadequate energy control procedures or the failure to properly implement them [OSHA...

One of the most heated debates in the process safety arena is… Do I have to have an emergency response team?  EPA has worked to answer this question by designating facilities as “responding” and “Non-responding” facilities.  Here is a nice flow chart to help… … HomeRead More »

Respondent is the owner and operator of the facility that produces, processes, stores, or handles more than 10,000 pounds of ethylene and more than 15,000 pounds of vinyl acetate monomer (Acetic acid ethenyl ester). The EPA inspected the Facility from January 16, 2020 to January 17, 2020, to determine the Respondent’s compliance with 40 C.F .R. Part 68. Ethylene and vinyl acetate monomer are...

In the past 4-5 months, I have received numerous phone calls and e-mails from friends/clients regarding their desire to hold an OSHA 10-hour course for their employees.  Most of this is driven by the idea that they believed, as they were told by some less than scrupulous consultants, that OSHA would accept their 10-hr card as meeting the required annual safety training for employees.  One...

This ammonia refrigeration process is equipped with an oil transfer pump that transfers fresh refrigeration oil from a barrel to fill up the compressor oil separators to the operating oil level. However, the oil pump has been idle for a prolonged period, with the electrical power connection incomplete.  Conversely, the associated piping system seems completed. One end of the oil distribution...

One way to reduce the risk of an ammonia leak is by monitoring for leakage through the analysis of the secondary coolant (often brine) for signs of ammonia. The secondary coolant in an indirect Ammonia system must be tested no less than twice a year. Information Paper IP-BPV-2021-08-01 outlines the requirements for a secondary coolant analysis that your TSASK inspector will enforce during...

One of the most dangerous tasks that occur within the battery limits of a covered process is “opening the process.”  This is commonly called a “Line Break” but also applies to vessels.  We won’t find a definition of “Line Breaking” in the PSM Standard; instead, we turn to OSHA’s Permit-Required Confined Space Standards (1910.146 and 1926.1201-.1213). ...

One of the biggest hurdles for an organization entering OSHA’s and EPA’s process safety standards is that some old OSHA standards are just NOT adequate based on the new level of risks.  This is most noticeable are with flammable liquid processes.  Take, for example, 1910.106, OSHA’s Flammable liquids standard.  It is “OK” for businesses that use flammable...

A licensed contractor installed two newly manufactured vertical machine-mounted air receivers for instrument air processes at a wood treatment facility in November 2020.  During a scheduled maintenance service after eight months of operation, cracks were located on the top head of each vessel, specifically at the head-to-bracket weld fillet welds. The cracking was in similar areas on both vessel...

This ammonia refrigeration system for the ice rink had been shut down, and the full ammonia charge (800 pounds) was being stored in the chiller, attached surge vessel, and the oil pot.  Three (3) days before the incident, a contractor was doing maintenance on the brine system to install a pH sensor in the brine pump discharge piping upstream of the pump’s discharge isolator (Image 4).  When...