PSM

Line Break Gone Bad (Cutting into live NH3 pipe)

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…...

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If we are not trending the findings from our 3-year PSM/RMP audits, WTH are we doing?

We see this far too often… a management system failure related to 3-year PSM/RMP audits. A company with multiple facilities should be “trending” its 3-year audit findings to IDENTIFY opportunities for improvement across the company. I did this years ago when I was a member of the Corporate EHS Team for a semi-conductor. And was…...

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CSB Issues Final Report into 2023 Fire at a Renewables Facility in Martinez, CA

Fire Severely Burned an Employee and Resulted in $350 Million in Damages The CSB released its final investigation report into the November 19, 2023, fire at the renewable diesel facility in Martinez, CA.  The incident seriously injured one employee, who suffered third-degree burns over most of his face and body and resulted in approximately $350 million in…...

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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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An MOC for relocating a production line in a food processing facility?

Victor Dearman Jr. CIRO, CRST No, it doesn’t involve anything with refrigeration. Same equipment, the same people, and a better layout to improve efficiency. So why would an MOC be required if it doesn’t impact refrigeration/PSM? Well, we have to think a little beyond equipment changes in the refrigeration system for a moment, or procedural

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

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…...

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One of the questions I got after the CSB Update on the PV failure in KY was…

“Why did they have a Rupture Disc and a Relief Valve together?” As I alluded to in my post regarding CBS’s update, this arrangement is fairly common but comes with some very SPECIFIC requirements. These requirements can be found in: But the top four (4) requirements, we as safety engineers should be looking for in…...

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API 520, Part II offers more guidance on “intervening valves” in a PRD path

I have shared the ASME and NBIC “code” requirements for these arrangements and it has already stirred a number of debates/questions; of which the API has offered some excellent guidance on this design. (emphasis by me)… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Hydrogen is used as a “refrigerant” @ power plants

A lot of folks may not know that Hydrogen gas is used as a refrigerant on generators at power plants. When I first started working on power plants in 2005, I was shocked at this practice and at how some plants managed these risks. I have never done work for the company involved in this…...

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RESPECT the Cl2

At approximately 9:45 p.m. on November 4, 2003, a maintenance employee went to the chlorine house to turn on the chlorination system. The chlorine house measured 3 feet, 10-inches wide by 5 feet, 10-inches long and was approximately 10-feet high. The water lines ran through a hole in the block wall. The hole in the…...

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Car Seal Program and Training Presentation UPDATED 2/2025

I have upload my REVISED Car Seal Program and the PowerPoint that goes with it to the Document Library – Chemical Process Safety folder…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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