OSHA PSM

Ammonia Refrigeration & PSM Contractor Qualification, Training Edition

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…...

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PSM – Emergency Preparedness (Preamble)

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…...

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OSHA PSM Citations @ Food Processor (NH3 & 131K)

The state of VA has fined a food processor $131,535 for a July 31, 2024 anhydrous ammonia leak that hospitalized 33 people. The leak triggered the evacuation of 287 employees working at the facility. Five of the 33 victims were hospitalized with serious conditions, 17 had serious but non-life-threatening conditions, and 11 had minor symptoms…....

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Does changing a chemical supplier require an MOC

Imagine the purchasing manager announcing at a staff meeting that the business is changing the supplier for one of your PSM/RMP-covered chemicals. There is nothing special about this chemical; it is a 100% pure solution/gas, so you think nothing is changing. But this chemical has come under a lot of questions by yours truly, and…...

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2 safety-critical devices in pressure testing our piping

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…...

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When Welding goes Wrong

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...

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Temporary SOP or a Car-Seal or Both?

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…...

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Never be too confident of our written SOPs/JSAs

We MUST never be too confident of our written SOPs/JSAs. There is a good reason why “Administrative Controls” are down on the Hierarchy of Controls. When we think our SOPs/Plans are infallible, our workers will show us a thing or two… And when we investigate adverse events and this leads us to “failure to follow…...

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When will the ammonia refrigeration industry finally embrace LOTO? (Part I)

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…...

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