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Last Updated on Monday, 20 February 2012 15:24
 
Challenging the NH3 Refrigeration & Electrical Classification
Safety Info Posts - Chemical Process Safety (PSM/RMP)

Most ammonia refrigeration personnel know their refrigerant is flammable, but most would also tell us that they do not have any "Hazardous Locations" (e.g. Class 1, Div 1 or 2 locations).  Most of these workers will explain their ventilation system is designed, installed, and maintained to ensure that NH3 never achieves 25% of it's LEL (e.g. 40,000 ppm), thus allowing the facility to escape the requirement of making their engine room an electrically classified area (e.g. hazardous location).  But in these technological days, this may no longer be the case...

 
A reverse look at Facility Siting and Change Management
Safety Info Posts - Chemical Process Safety (PSM/RMP)

An older post, with updates...Ever since the 2005 BP Texas City tragedy, refineries and chemical plants have been working diligently to review “facility siting” risks for their facilities.  As with all of the PSM elements, many of us took this new focus as a learning opportunity.  We had all done something we called “facility siting” in our Process Hazards Analysis, but in the early 1990’s many of us “did not know what we did not know” in regards to what a real facility siting analysis was suppose to look like. 

 
Flashlights Improperly Marked with MSHA Emblem (THEY ARE intrinsically safe - just mislabeled)
Safety Info Posts - Safety Alerts

msha

 
21 Incidents & 3 Updates (2/16/12)
Safety Info Posts - Incident Alerts
 
Video of the Week #7 - Horseplay
Safety Info Posts - FREE Video of the Week

 

 
Roof work and proper Fall Protection
Safety Info Posts - OSHA Compliance Posts

Let me be clear... I am not a Fall Protection expert in any stretch of the imagination, so I am all about engineering out the fall hazards whenever possible.  A few weeks ago we received a call from a new client who had just suffered a bad accident where one of their star employees was on the roof working on a piece of equipment.  The roof is perfectly flat and has a raised edge of 27" around it.  The employee was working on an environmental control device and as he was trying to pull some duct work up from the roof penetration, he began to step back in order to get the duct work up and out of the roof hole - something he had done dozens of times in the past couple of years.  Unfortunately, this time he did it with his back to the edge and as he stepped back with this heavy piece of duct work that was hung up in the penetration, it broke free and he and the duct work took a 30' fall over the edge.  He survived merely because he flip in the air and landed on the fiberglass duct work which acted as a cushion.  A fractured sternum and several broken ribs and he was back to work four days later on light duty.  The results could have EASILY been a fatality; he knows it and the company knows. 

 
Is the act of loading/unloading a PSM/RMP chemical exempt from OSHA/EPA enforcement?
Safety Info Posts - Chemical Process Safety (PSM/RMP)

Is the act of loading/unloading a PSM/RMP chemical exempt from OSHA/EPA enforcement?  Absolutely not!  Somewhere this little fib began and it has spread like wildfire.  If you have a release of your HHC/EHS during unloading or loading, rest assured OSHA and/or EPA can investigate and inspection, and here's why...

 
How many threads of a bolt must be showing outside a nut to meet RAGAGEP?
Safety Info Posts - Chemical Process Safety (PSM/RMP)

Some may claim this to be a trick question.  I assure you it is not meant to be, but as I will point out in this posting, having too much bolt extending beyond its nut can be an issue, as well as not having the bolt flush with the outer surface of the nut.

 
UPDATE - INCORRECT Metal Scaffold Board ALERT
Safety Info Posts - Safety Alerts

Layher boards

Ladies and gentlemen,
This false alert is from 2006. Layher has been falsely accused of having a cracked board. Layher does not even weld in that area.  You can find the retraction of ISI (the originator) and correction at Layher's web site www.LayherUSA.com or contact Layher under This e-mail address is being protected from spambots. You need JavaScript enabled to view it .
Best regards,

Frank Frietsch

CLICK HERE to see the correction from Layher

CLICK HERE to see the correction from Industrial Specialist LLC

 
Newsletter (2/19/12)
Safety Info Posts - Newsletters
 
Safety Poem
Safety Info Posts - Motivational Safety Materials

Here we stand

down and dejected

 

The short cut he took

was not detected

 

The life he lived

has now been rejected

 

If only our safety rules

he would have respected

 

Author: Russ Baxter

 
Can a PHA done for OSHA's PSM be used for EPA's RMP Compliance?
Safety Info Posts - Chemical Process Safety (PSM/RMP)

If your Program 3 process is also subject to OSHA PSM, you can use the PHA conducted for OSHA PSM compliance as your initial process hazard analysis for EPA purposes, provided you conducted your initial OSHA PHA prior to May 26, 1997...

 
Change(s) that REQUIRE a PHA revalidation
Safety Info Posts - Chemical Process Safety (PSM/RMP)

There is some language in the EPA's Risk Management Plan program requirements that tends to cause some confusion...

The owner or operator of a stationary source shall revise and update the RMP submitted under §68.150 as follows:

(5) Within six months of a change that requires a revised PHA or hazard review

So when are we required to "revise our PHA" other than when we have to do our 5-year revalidation?

 
26 Incidents & 2 Updates (2/20/12)
Safety Info Posts - Incident Alerts
 
Newsletter (1/20/12)
Safety Info Posts - Newsletters
 
Photo of the Week #7 - When to know its time for a new Hard Hat
Safety Info Posts - OSHA Compliance Posts

hardhat dates

 
 

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