Although this advisory circular is for Commercial Human Space Flight, it can be applied to High-Risk activities in an industrial setting, such as process safety matters. The single most significant gap I see in past PHAs is the Human Factor(s) analyses. In some cases, I cannot even recognize the methodology used in the PHA. In the year 2024, it is about time we begin to take the HF analysis and the...

How much time does the owner or operator of a stationary source have to submit a correction to a Risk Management Plan when the emergency contact information changes? … HomeRead More »

It is suggested that LATENT ORGANIZATIONAL failures are analogous to the “resident pathogens” within the human body, which combine with external factors (stress, toxic agencies, etc.) to bring about disease. Like cancers and cardiovascular disorders, accidents in complex, defended systems do NOT arise from single causes. They occur through the unforeseen (and often unforeseeable) concatenation...

This EPA CAFO has me wondering who upset the U.S. EPA. There are only two (2) violations; one is the most cited RMP violation in the past seven years and is quite minor; the other was one of the newest RMP requirements, and those two violations netted a $93,000 citation. Respondent is the owner and operator of a facility that operates a refrigeration process that uses Anhydrous Ammonia in quataties...

On May 6, 2021, the Environmental Protection Agency (EPA) published a Final Rule listing R‒452B, R‒454A, R‒454B, R‒454C, and R‒457A as acceptable substitutes, subject to use conditions, for use in residential and light commercial air conditioning and heat pumps. These refrigerants are flammable and are classified as belonging to ANSI/ASHRAE Standard 34 safety group A2L. The listed substitutes are refrigerant...

A few weeks ago, I gave a sneak peek at what was coming: Manufacturer’s Limitations of Sulphur Sticks. Today, it arrived in the form of an OSHA LOI.  A sulfur stick is a tool used to find ammonia gas leaks. Sulfur sticks, when burned, react with ammonia gas to make a visible smoke and are generally used near process equipment and piping to detect leaks. The company has an established procedure...

Does all fixed/portable/mobile equipment that is installed or enters a Hazardous Location (HAZLOC) have to be “certified” and “labeled” as being acceptable for that specific HAZLOC? The blunt answer is YES! But in today’s working world and global economy, I am seeing a lot of foreign approvals for electrical equipment that is not by one of OSHA’s NRTLs. I am also,...

As I have said for years, we may never know where the nasty rumor came from that installing threaded and/or flanged piping is easier and cheaper than welded pipe.  That is a “pipe dream”… LOL see what I did there? For example, did you know that if the piping will be pneumatically pressure tested, then ASME B31.3/.5 requires that ALL threaded, bolted, and other mechanical joints…...

One of the significant deficiencies we find in our audits/investigations is the lack of meeting ASME B31.3/.5 to install process piping. I have written about this topic for decades, and I still get inquiries monthly about this standard and its critical role in real process safety management. For those who attend my 5-day Advanced PS Course, this single topic gets more questions/discussion than any...

Those of you who practice in the Process Safety arena are well aware of OSHA’s and EPA’s requirements to have “written procedures to maintain the on-going integrity of process equipment.” (1910.119(j)(2). However, OSHA and EPA also have a section in their Mechanical Integrity elements titled “Quality Assurance.”  1910.119(j)(6) Quality assurance. 1910.119(j)(6)(i)...

Most safety professionals are well aware of the many medical evaluations called out in OSHA standards, such as the medical evaluations for workers wearing respirators, emergency responders, etc.  But we also have a medical evaluation requirement in Process Safety Management that plays a critical role in our piping Quality Assurance (QA) program.  When using either ASME B31.3 or 31.5 to design,...

I see severe risk-taking regarding “safety assumptions” in process safety in my travels. I guess I am just “old school” and believe that every Pressure Vessel (PV) deserves its very own Pressure Relieving Device (PRD). But in today’s economy, where “costs” can be a driver in decision-making, I have experienced numerous scenarios where a single PRD will be “assumed”...