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Respondent owned and operated two food warehousing facilities. One is used for food manufacturing and refrigerated warehouse and storage and the other is used for refrigerated storage. Respondent, as owner/operator of the Facilities, has handled and/or stored anhydrous ammonia at an amount greater than the threshold quantity of 10,000 pounds in a process since at least 1999 at the refrigerated warehouse...
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If you have been too busy to read the latest edition of NFPA 2112 (e.g. 2018), oh boy have you missed some fun reading. For the most part, the standard is the same, but there are some significant nuggets that stand to impact a lot of facilities, especially those who allow “emblems” on their FRC. Yep, that day has arrived… no longer can we have “emblems” that...
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Once again I go to the well that just keeps on giving guidance… the International Fire Code (IFC). And again I do this as OSHA nor EPA have any standards for Chlorine when the amount is below the 1,500 pounds for OSHA’s PSM standard to apply. Of course, there is EPA’s RMP General Duty Clause, but this provides us with zero help in establishing the minimum design and operational standards....
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When you use your isolation device and verify the energy is at a ZES only to find out that this is your lockout device…
Guess now we need to begin verifying our lockout device actually functions as such!
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I came across an interesting “Annual HAZMAT Report” for New York City and in it was a listing of the RMP facilities within the cities boundaries. Who would have ever guessed there were 366 RMP facilities within NYC borders!
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As I have said many times, OSHA’s 1910.106 is badly outdated, so for those who are looking for that extra edge to improve flammable liquids process safety (not just OSHA PSM/EPA RMP compliance, but real process safety), we should consider utilizing the 2018 International Fire Code (IFC). I should also point out that a fair number of states have or will soon be adopting this 2018 version, so for...
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The 2018 IFC has some great design requirements for flammable liquids (as does NFPA 30). Abiding by this 2018 IFC, Chapter 57 would provide a much higher degree of safety as compared to meeting OSHA’s 1910.106. So I have broken down and discussed these IFC requirements for those looking to improve their flammable liquid piping systems:
(emphasis added by me)
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Here we sit in the year 2018 and here I sit posting about the use of “low-melting-point materials” for use in flammable liquids and flammable gases piping systems – oh the insanity, but this debate seems to happen far too often these days! I have been working with Hazardous Materials, most notably Flammable Liquids and Gases (FLAGs) since 1992 and from my very first fire science...
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Respondent owned and operated a petroleum refinery and it’s RMP lists covered processes subject to Program 3 requirements, including the Ultracracker (ULC) unit which consists of three sixty-three-foot-tall pressure cylindrical reactors, each containing five individual catalyst beds. The hydrocracking reaction converts the larger hydrocarbon chains into smaller, more valuable hydrocarbons. On...
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The facility uses xylene as a cleaning agent to clean the reactors. Xylene is an extremely hazardous flammable substance, and is stored at the facility. On August 14, 2017, at 11:24am, an operator was cleaning the RX-2 reactor with xylene between tolling processes. The operator overfilled the reactor with xylene, leaving the reactor without a vapor space. The pressure increased causing the...
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Due to a September court decision that vacated the RMP Amendments effective date delay, and the court’s expedited issuance of its mandate, the FINAL RMP AMENDMENTS RULE IS NOW IN EFFECT. Because the 2017 rule contains a schedule of compliance dates for many of the major provisions, the issuance of the mandate does NOT create current compliance obligations for some parts of the...
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