In the 90s, I was working a turn-around at a sister facility and learned the niftiest trick related to Double Block and Bleed (DB&B).  When the isolation valves and the bleed valve were nearby (i.e., a couple of feet or less) of each other, they would use just a single lock to secure the isolation.  They would use a LOTO cable to pass through all three (3) lockout devices, with the isolation...

Respondent owns and operates an ammonia refrigeration system at its meat processing facility which began operation in February 2019. The ammonia refrigeration system had an initial charge of 17,000 pounds of anhydrous ammonia when operations began, making the facility subject to requirements of Chemical Accident Prevention Provisions in accordance with 40 C.F.R. § 68.10(a) and the requirements of Program...

The proposed OSHA standard will NOT apply to all public sector emergency responders. The scope is limited to Emergency Service Organizations (ESOs) and responders under OSHA’s jurisdiction. ONLY public ESOs that are in state plan states are under OSHA’s jurisdiction and therefore the analysis excludes public ESOs and responders in non-state-plan states. The following states and territories have state...

This has been a huge battle in the power generation and semi-conductor industries!  To me, it is very clear – as soon as the trailer is “dropped”, meaning the semi that was pulling the tube-trailer has been detached, then that trailer becomes a “stationary process”.  EPA has several documents making this point and for those who visit my PSM/RMP Case Page you...

Formaldehyde is not specifically listed with a concentration cutoff, but is listed with the QUALIFIER “solution”. Can the partial pressure exemption be applied to formaldehyde solutions? … HomeRead More »

The definition of a process would seem to say that my process is part of the larger company’s process because they are interconnected. Why can’t the larger company just include my process in its RMP? … HomeRead More »

Must a stationary source owner or operator consider the amount of ammonia present in ammonium hydroxide that is contained in a process when determining whether the threshold for ammonia is exceeded? The list of regulated toxic substances at 40 CFR Section 68.130 includes BOTH “ammonia (anhydrous)” and “ammonia (conc 20% or greater)” but does not include a specific listing for...

Under OSHA’s Process Safety Management Standard, an exemption is provided for the atmospheric storage of flammable liquids. Why has EPA decided NOT to include this exemption under the risk management program regulations? … HomeRead More »

I have written often about this topic and it is without a doubt the most questioned/challenged topic in my 5-Day Advanced Process Safety course.  Several toxic substances are listed as regulated substances under 40 CFR §68.130 with CONCENTRATION QUALIFIERS (e.g., “conc 37% or greater”).  The four(4) regulated substances that have concentration qualifiers are: Ammonia (conc 20%...

The wonderful team of process safety engineers “across the pond” in the UK have published an EXCELLENT and MUST READ guide on how a business can develop their process safety LEADING indicators.  This is a MUST READ for those PS Leaders who are looking for ideas on what and how to measure PSM/RMP Leading Indicators.  The guide methodically teaches the reader how to go about identifying...

HAZMAT containers used for flammable, corrosive, and toxic liquids and gases will have a pressure/vacuum relief valve to prevent damage to the tank from changes in the internal pressure. These valves MUST be inspected and maintained in line with the manufacturer’s instructions.  Some valve designs require a special tool to dismantle them for servicing. Investigations by HSE found a technician...

Investigation into an explosion of a High-Voltage (HV) circuit breaker indicated that recently carried out maintenance may have been a causal factor. The incident resulted in catastrophic failure of the HV circuit breaker leading to fire/explosion and could have resulted in fatal injuries. Maintenance of HV and LV circuit breakers typically involves both the cleaning and lubricating of the operating...