RMP

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 […]

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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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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Chemical Exposures from Industrial Valve and Piping Systems

Fundamentally, employers and employees must be alert to the fact that working with a “closed system” does not always ensure safety. Operations involving the opening of valves or pumps on otherwise closed systems or working on such equipment that is not isolated or locked/tagged out are particular sources of danger. When a normally closed system…...

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OSHA cites API 510, 6.2 Inspection During Installation

I first wrote about this API 510 requirement in July 2019, and now OSHA appears to have caught up with this requirement; this year, they issued their first citation related to this requirement. Of course, the citation was associated with a process covered by PSM. Here is the API 510 requirement for newly installed pressure…...

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EPA RMP citations @ seafood processing and distribution facility (NH3 & $220K)

Respondent operates a seafood processing and distribution facility in New Bedford, Massachusetts that uses anhydrous ammonia in a refrigeration “process” as defined by 40 C.F.R. § 68.3, in a series of interconnected pipes and vessels at the Facility (the “Process”). According to the respondent’s 2012, 2013, 2014, 2015, and 2016 Reporting Year Tier II reports,…...

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EPA RMP citations @ agricultural products facility (NH3 & $119K)

Respondent is the owner and operator of a facility that stores, manufactures, and distributes agricultural products, including anhydrous ammonia. The threshold quantity for anhydrous ammonia, as listed in 40 C.F.R. § 68.130, is 10,000 pounds. On or about August 22-23, 2023, a representative of the EPA conducted an inspection of the Respondent’s Facility to determine…...

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SAFETY INTEGRITY LEVEL (SIL)

As barriers or safety systems can fail, it is essential to design them well and understand their reliability, which is expressed in an SIL rating. The Safety Integrity Level relates to the Probability of Failure on Demand (PFD). We use complete orders of 10 to describe the reduction factor:… Membership Required You must be a...

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