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Engineering & Code Review; What is it and Why do it?
I have spent much time with clients doing "Engineering and Code Reviews." These have been instrumental in avoiding many issues when it comes time for the INITIAL PHA. Depending on the process size and complexity, these can take 0.5 - 3 days, but that time is spent ensuring the primary containment systems and all the layers of protection that come into play for the PREVENTION-PROTECTION-MITIGATION of events at least meet the design codes applicable to the process. But the real advantage is... Membership Content
NFPA 30, Section 27.7 Testing of Piping Systems
It is rare; I can not recall ever disputing NFPA in any of their guides/standards/codes. However, section 27.7 of NFPA 30 is worded incorrectly and needs to be called out as it poses significant risks if followed by the letter. Section 27.7 covers the pressure and leak testing of "flammable liquid" piping circuits. Although I am thankful for NFPA including this in NFPA 30, some users who may not know better may place their people or contractors in harm's way. Here is the issue: NOTE: This requirement goes back ever since NFPA 30 included this pipe testing requirement Enforcement Guidance Under OSHA's Recordkeeping Regulation When First Aid, Active Release Techniques (ART), and Exercise/Stretching Are Used to Treat Musculoskeletal Injuries and Illnesses
May 2, 2024
This memorandum provides guidance to help determine whether musculoskeletal injuries and illnesses are recordable under OSHA's injury and illness recordkeeping regulation at 29 CFR 1904 when the only treatment given is first aid, Active Release Techniques (ART), and/or exercises and stretching. NIOSH updates MultiVapor™ Version 2.2.6 Application
MultiVapor™ has been updated to resolve the errors users experienced with a missing MSSTDFMT.DLL file, and other minor typographical errors. MultiVapor™ is a computer tool for estimating breakthrough times and service life of air-purifying respirator cartridges manufactured to remove toxic organic vapors (OV) from breathed air. It can also be used for larger filters and for carbon beds of any size prepared for laboratory studies. MultiVapor 2.2.5 was updated in June 2018. This latest version incorporates 26 new compounds, including CN, HDMI, and MMA. The library now contains over 750 compounds. A breakthrough time is the time following the first and continuous use of a cartridge after which the user of the cartridge could be exposed to a selected concentration of a harmful vapor. This is the consequence of the cartridge being used up. Service life is the breakthrough time with, possibly, a safety factor applied. MultiVapor™ is intended to help an industrial hygienist, or other qualified person set cartridge change-out schedules. It is NOT a substitute for regulatory requirements or professional judgments. Users must assume full responsibility for any application of the MultiVapor™ computer software. No warranties related to the software are expressed or implied by the National Institute for Occupational Safety and Health (NIOSH) or its contractors. This software is intended to provide estimates based on the latest scientific information. The accuracy of any such estimates will depend in part on the accuracy and validity of the data entered by the user. CLICK HERE FATAL flashfire in gasoline storage tank (Flammable atm)
On May 2, 2023, an employee working for a gas station and convenience store arrived to talk to a coworker (the employer) about payment for the building he leases. The employee asked the coworker if he could help him apply a fuel tank liner. The employee climbed inside the tank and plugged in his own light into an extension cord. EPA RMP GDC citations @ seafood processing and cold storage facility (NH3 & $20K w/ $129K SEP)
Respondents owned and operated a seafood processing and cold storage warehouse facility. The Facility is one building that consists of two separate spaces on either side of a dividing wall. One side of the Facility is used for seafood processing and packaging. The other side of the Facility is a cold storage warehouse used to store the packaged seafood. The Facility is located alongside Gloucester's Inner Harbor in a large and densely populated residential area. It is within half of a mile of hundreds of homes, restaurants, and other businesses and within a quarter of a mile of an elementary school and at least two houses of worship. At the time relevant to the violations alleged herein, Respondents used anhydrous ammonia in two refrigeration systems at the Facility. The ammonia refrigeration system on the processing and packaging side of the Facility uses approximately 1,543 pounds of anhydrous ammonia, and the ammonia refrigeration system on the storage side of the Facility uses approximately 7,075 pounds of anhydrous ammonia. Accordingly, Respondents "stored" and "handled" anhydrous ammonia, subject to the General Duty Clause. On September 15, 2022, EPA conducted an inspection at the Facility. The purpose of the Inspection was to determine whether Respondents were complying with Section 112(r) of the CAA and the Emergency Planning and Community Right t o-Know Act. The EPA inspectors toured the Facility's perimeter, roof, the ammonia machinery room ("AMR") for each refrigeration system, cold storage spaces on the first and third floors, and the chemical storage area. The Inspection and EPA's review of information provided by Respondents revealed several potentially dangerous conditions relating to the refrigeration systems. Add ASME B31.12 to the list allowing "intervening valves" in the PRV path
If you want a spirited process safety debate, simply mention the practice of having "intervening valve(s)" before or after a Pressure-Relieving Device (PRD). There are some who swear that it is not allowed, but in fact, it is. This is how I learned about the "Car-Seal" program early in my career. ASME B31.12 is one of those RAGAGEPs that allows this practice WHEN it meets certain criteria, such as a Car-Seal Program. Essential Features of the Emergency Plan (ASME B31.12)
Each operating company shall establish written procedures to minimize the hazard of an emergency. The procedures shall provide instructions to operating and maintenance personnel. The procedures shall describe the following:
Writen Operational, Maintenance, and Emergency Plan(s) for Industrial Hydrogen Piping (ASME B31.12)
As I dig deeper into ASME B31.12, Hydrogen Piping, I continue to find nuggets of best practices for HAZMAT piping. ASME B31.12 requires each operating company having industrial piping, pipeline, and commercial and residential systems to have Operational, Maintenance, and Emergency Plan(s) that include the following: OSHA's Heat exposure standard
On April 24, 2024, the department's Occupational Safety and Health Administration presented the draft rule's initial regulatory framework at a meeting of the Advisory Committee on Construction Safety and Health. The committee, which advises the agency on safety and health standards and policy matters, unanimously recommended OSHA move forward expeditiously on the Notice of Proposed Rulemaking. As part of the rulemaking process, the agency will seek and consider input from a wide range of stakeholders and the public at-large as it works to propose and finalize its rule. |
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I am proud to announce that The Chlorine Institute and SAFTENG have extended our"Partners in Safety" agreement for another year (2024) CI Members, send me an e-mail to request your FREE SAFTENG membership
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