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UPDATE on OSHA's PSM Revisions (May 2016)
Last week OSHA shared an update on where they are at with their desired revisions to the PSM standard (1910.119).  Some of the potential PSM Revisions include:   Atmospheric Storage Tanks Oil and Gas-Well Drilling, Servicing, and Production Chemical Reactivity Safer Technology and Alternatives Additions to Appendix A Chemicals Dismantling/Disposal of Explosives Define/Updating RAGAGEP Mechanical...
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Diesel Fuel Flash Fire?
Back on March 4, 2016 a contractor/truck driver was transferring “diesel fuel” of some type from a storage tank to his truck when there was a flash fire.  He received 2nd and 3rd degree burns over 50% of his body and has since passed away from his injuries.  When I saw this incident in my Incident Alerts I was very curious as to how diesel fuel could be involved in a flash fire...
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Pressure Differential Between Safety or Safety Relief Valve Setting and Pressure Vessel Operating Pressure (NBIC)
We have seen this far too often… operating ranges that are too close to RV set points.  Here is some excellent guidance from a great pressure vessel RAGAGEP, the National Board (NBIC-Parts 1-3) on how to establish the DESIGN characteristics for a pressure vessel based on the OPERATING PARAMETERS the vessel will be operating in… … HomeRead More »
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2016 Photo of the Week #19 (Car Seal and RV Venting)
Now, see if you can find the mistake.
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2016 Video of the Week #19 (Dangers of Excavating - Electrical)
 
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How strong is your MI "Quality Assurance Program"?
Both OSHA and EPA require PSM/RMP facilities, more specifically covered process(s), have a QA program in their Mechanical Integrity (MI) Program… 1910.119(j)(6) Quality assurance. 1910.119(j)(6)(i) In the construction of new plants and equipment, the employer shall assure that equipment as it is fabricated is suitable for the process application for which they will be used. 1910.119(j)(6)(ii) Appropriate...
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Does 1910.134 require a separate fit test for each harness where respirator wearers are required to use different harnesses, depending on their job task? (OSHA LOI)
Background: You’ve pointed out that in some workplaces, employees may be required to wear a different harness on the same manufacturer’s model facepiece and sealing surface for different work scenarios such as different work modes (negative vs. positive pressure) or for flame and heat protection. During our meeting, we discussed… One respirator model has two harness options that connect...
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60 incidents & 0 updates (5/3/16)
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Pipe Flange
Pipe flanges and process safety
As a process safety professional, what do we see and what comes to mind when we see a pipe flange like the one shown here?  In this small and simple picture, how many sections of OSHA’s PSM standard (or EPA’s RMP rule) impact this pipe flange; better yet, can we name all the RGAGEPS that would impact this pipe flange?  Look closely as this is sort of a “special” flange!...
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2016 Photo of the Week #18 (Human Factors & Color Coding)
 Who sees it?
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2016 Video of the Week #18 (Atmospheric Tank Launch... again)
I just hope I can convince other safety professionals that atmospheric storage tanks containing flammable liquids are EXTREMELY DANGEROUS and deserve our respect when it comes to DESIGN, CONSTRUCTION, FACILITY SITING, and MAINTENANCE (e.g. MI), and RELIEF PROTECTION.  I recently had a lawyer attempt to make an argument that if these tanks were so dangerous then why did OSHA exempt them from their...
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EPA RMP Citations @ refinery (Flammables & $718K)
Complainant alleges that Respondent violated the provisions identified herein and seeks the assessment of a civil penalty. Respondent owns and operates a refinery. At all times relevant to this action, Respondent processed, handled. and stored regulated flammable substances listed in 40 C.F.R. § 68.130 in a mixture at its facility. At all times relevant to this action, Respondent had eight covered...
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