This stunt has to be one of the riskiest I have seen in my 30+ years in Process Safety. They knew it was a live line, but why it was live is anyone’s guess. It looks as if this may be a “Demolition” job without a pump down, or maybe the plant was just down…...
Most companies will go to some degree of lengths in selecting “qualified” contractors to include things such as job examples, a list of qualifications, require subscription to the ISN network, etc. Even then, though, sometimes bad apples slip through the cracks if the company needing a “qualified” contractor doesn’t develop a scope or set of…...
Respondent operated a facility that utilizes anhydrous ammonia to provide cooling capabilities to processing, shipping, cooler areas, silos, and chillers for its beef and meat products. On March 30, 2022, EPA performed an inspection of the Facility to evaluate compliance with the Comprehensive Environmental Response, Compensation and Liability Act (“CERCLA”) Section 103, EPCRA Sections 304-312,…...
How dare OSHA even mention “torque” as part of a PSM QA program…… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
This was published 30+ years ago, but it makes so much sense I thought it was fitting to share far and wide again. Each employer must address what actions employees are to take when there is an unwanted release of highly hazardous chemicals. Emergency preparedness or the employer’s tertiary (third) lines of defense are those…...
Respondent operated a facility (the “Facility”) to process, store, and distribute prepackaged salads, fresh-cut vegetables, and other food products. At all times relevant to this CAFO, Respondent produced, used or stored more than 10,000 pounds of ammonia (anhydrous) at the Facility and was subject to the requirements of CAA § 112(r)(7). At all times relevant…...
Respondent owns and operates a facility that wholesales animal feeds, fertilizers, agricultural chemicals, pesticides, seeds, and farm supplies, including agricultural anhydrous ammonia. On or about August 9, 2023, EPA inspected the Respondent’s Facility to determine compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68. Information gathered during the EPA inspection revealed that…...
It is great when I can convince an organization to pressure test and leak test its process piping. However, if this task is not done according to the book, we may have created a serious hazard. Two (2) safety-critical devices are often overlooked during pressure and leak testing, and missing either one or both can…...
This is why we MUST have a Quality Assurance process in our piping installations when welding joins the pipe. The same applies to the construction process vessels; however, most of those are “shop-built,” and we are outside the scope of those vessels. But a “field-erected” vessel would fall into our sphere of control…. Membership Required...
The arrangement below is very common in processes/systems. This simple yet common arrangement causes havoc in hazard analyses. As the title states, is this arrangement managed with a Temporary SOP, a Car-Seal, or Both? The issue is that the motorized valve is tied to a Hi-Hi level alarm and interlock. When the vessel archives its…...
Victor Dearman Jr. CIRO, CRST One of the challenges to my post was “What if the flagging tape was to indicate that the valve was in an abnormal position?” This was followed up with a challenge as to whether or not anything forbids such a method. Operating procedures should be designed to meet the requirements…...
By: Victor Dearman Jr. CIRO, CRST Flagging tape is not LOTO! And never has been. I would bet good money the operating procedure for this compressor has LOTO covered, but those are just documents to look good in a binder sitting on a shelf collecting dust because they are viewed as a necessary evil to…...
