Back in 2015 I wrote about changing the “service” of a pressure vessel and all that should be considered in this change. Late last year my team and I ran across a very common error in “changing the service”, albeit the change was an actual change of location. Here’s what happened…

We are no longer surprised when we come across a “process” which is not a PSM-covered process because the facility has managed the quantity of their HHC below OSHA’s threshold. However, from a risk perspective, having 9,975 pounds of an HHC versus having 10,000 pounds does not lessen our process or personnel risks, but that is another discussion for a rainy day. Recently we came across an even more unique situation that nearly resulted in multiple contractors receiving serious burns when the flammable vapors ignited. The process was not covered by PSM/RMP because the “feed stock” was a Category 4 flammable liquid with a FP just under 190°F; however, this Category 4 flammable liquid was being heated to a temperature well above it’s flash point. Here’s what happened and how OSHA was at a loss to take action…

  1. CSB Releases Preliminary Findings into WRONG Chemical - WRONG TANK incident in KS

  2. "Human Factors" matter in Process Safety... and @ crosswalks!

  3. Line Break/Process Opening GONE BAD (flammable butylene mixture)

  4. ASME B31.3 makes it clear that hydrostatic leak testing is PREFERRED

  5. EPA RMP Amendments proposed delay until February 19, 2019

  6. OH EPA offers nice "flow chart" for RMP Program Classification

  7. State of CA ups the Refinery Contractor Safety Training requirements via state Hazardous Materials Management Code

  8. OSHA's intent with the PSM "retail exemption"

  9. OSHA, PSM, "Retail", and LOI's

  10. UPDATE: Final Amendments to the Risk Management Program (RMP) Rule

  11. 738 pound Chlorine (Cl2 ) Release Investigation Report

  12. EPA Extends Comment Period on Risk Management Plan Rule

  13. Right-To-Know Website is BACK thanks to the Houston Chronicle

  14. It's a bird, It's a plane, no... it's a pressure vessel (BLEVE 2017)

  15. EPA amended RMP "Availability of information to the public"

  16. Worst-case release scenarios for toxics and flammables involving the same process

  17. Yep... it's just ammonia (OSHA Database Accidents)

  18. Line Break(s) gone bad (Chlorine)

  19. 2016 OSHA PSM activity by Industry Sectors

  20. Is your plant speed limit based on engineering or a whim

  21. 2017 Seminar Fest Process Safety Manual and ppt (Student Access)

  22. Aqueous solutions of HCl are NOT covered under the PSM standard regardless of quantities

     

  23. Line Breaking (e.g. Process opening) is like handling a gun

  24. EPA's 3rd Party Audits

  25. How will the RMP rule impact changes to OSHA’s PSM update? (EPA Letter)

  26. EPA explains the changes to the FINAL RMP Amendments local emergency response coordination requirements

  27. EPA clarifies the new "public information" requirements for their FINAL amendments of their RMP Rule

  28. EPA explains the new Incident Investigation provisions in their Final RMP Amendments

  29. EPA explains Safer Technology and Alternatives Analysis (STAA)

  30. EPA explains the new RMP rule Third Party Audit requirements

  31. EPA explains the new RMP rule provisions COMPLIANCE DATES

  32. EPA issues two (2) letters regarding Ammonium Nitrate

  33. U.S. Court of Appeals for the Fifth Circuit agrees that a control room's positive pressurization unit (PPU) is part of a "covered process" (PSM)

  34. U.S. Court of Appeals for the Fifth Circuit finds that OSHA can't cite for violations that were over 6 months old (PSM)

  35. Changes to the 2015 IFC impact “Mechanical Refrigeration” requirements in a BIG WAY

  36. EPA's Amended Risk Management Plan Rule (December 2016)

  37. A breakdown of EPA's amendments to their Risk Management Plan rule (2016)

  38. Breaking down EPA's new Emergency Response requirements for RMP facilities

  39. EPA finalized it's Risk Management Plan Amendments

  40. 2015 International Fire Code (IFC) and Hotwork Requirements

  41. AWS updates Specification for AWS Certification of Welding Inspectors

  42. EPA issues new RMP FAQ - NFPA 4 Criteria

  43. 2016 RMPs Top 10 Lists (By Chemical & Pounds in Process)

  44. RMP #'s by State

  45. ASME B31 series for piping - Fluid Service Categories

  46. OSHA Line Break Incidents and Citations

  47. EPA recently offered more on "co-location" of two (2) non-connected processes

  48. The holidays are upon us, so it is time for our piping "holiday inspection" (sarcasm)

  49. FM Global revises their Hot Work Data Sheet

  50. OSHA's 1910.119 Appendix A, Sulfur Dioxide (liquid)

  51. OH EPA offers some RMP Program Level scenarios

  52. Coast Guard issues Safety Alert regarding “nuisance alarms”, a lesson in process safety as well

  53. Report to the University of Hawaii at Manoa on the Hydrogen/Oxygen Explosion of March 16, 2016

  54. The Importance of Root Cause Analysis During Incident Investigation (OSHA Fact Sheet)

  55. How well do you know your process piping?

  56. Enforcement Delay Notice Note: OSHA is not implementing the July 2015 retail exemption memo

  57. The Use of Metrics in Process Safety Management (PSM) Facilities (OSHA Fact Sheet)

  58. UPDATE on Chemical Facility Anti-Terrorism Standards Top-Screens and Security Vulnerability Assessments (SVA)

  59. Senator Boxer (D-CA) sends letter to EPA calling on the agency to strengthen their RMP revisions

  60. CSB Presentation on West Fertilizer Lessons Learned

  61. OSHA loses their battle to redefine "retail" in the PSM Standard (1910.119)

  62. RMP Accident Data (2006-2016)

  63. Catastrophic Failure of 500 ton Atmospheric Refrigerated Anhydrous Ammonia Tank (2016)

  64. Can my PSM covered process be a RMP Program 1 process?

  65. Do I have to count the quantities of my RMP covered chemicals in railcars sitting on my site?

  66. FATAL Hotwork Explosion @ pipeline station ($1.6 million for failure to follow facility procedures)

  67. HFO-1234yf refrigerant may end up in New Zealand Refrigerators and Home AC's

  68. California Governor’s Office of Emergency Services extends CalARP Program 4 written comment deadline

  69. Can a facility alter its highly hazardous chemical storage practices to avoid PSM?

  70. OSHA publishes DRAFT "Process Safety Management for Small Business Compliance"

  71. Ammonia Refrigeration, Diffuser Tank and Uniform Mechanical Code (UMC)

  72. Ammonia Refrigeration, Diffuser Tank and NFPA 1

  73. Another example of why our Line Break Permitting should cover MORE than just our PSM/RMP covered process(s)!!!

  74. Fertilizer Canada has gotten serious about Facility Siting for NH3 Ag facilities!

  75. NFPA's 2017 Edition of NFPA 70 (NEC) will impact facilities handling Anhydrous Ammonia

  76. RMP Enforcement Data from Ohio EPA EPA announces NEW National Enforcement Initiative: Reducing Risks of Accidental Releases at Industrial and Chemical Facilities (Fiscal Years 2017-19)

  77. Is the state of IL moving fast enough to improve process safety @ NH3 Ag retail facilities?

  78. Appropriations Bill Blocks OSHA's efforts to revise the "retail exemption" as it applies to Anhydrous Ammonia @ Fertilizer Distributors

  79. OSHA Memo - PSM Chemicals and Covered Concentrations of Listed Appendix A Chemicals (July 18, 2016)

  80. Dow Line Break/Equipment Opening Presentation

  81. CSB Board Members Adds Preventive Maintenance and Emergency Planning and Response to Most Wanted Safety Improvement Programs

  82. New twist in DOT unloading/loading and PSM/RMP Threshold Determination

  83. California Announces Major Regulatory Proposal to Improve Safety at Oil Refineries

  84. NBIC’s NATIONAL BOARD BULLETIN hits a homerun for process safety practitioners!

  85. FY 2016 U.S. Chemical Safety and Hazard Investigation Board Management Challenges (EPA Office of Inspector General)

  86. Managing boilers attached to a PSM/RMP covered process

  87. Pressure Testing gone bad (Fatality)

  88. NBIC introduces a NEW Certification Mark for Pressure Relief Valve Certified Testing Organizations

  89. OSHRC rules that a boiler providing steam used in safety systems is part of the PSM Covered Process

  90. "Routine Process Openings" can be hazardous as well

  91. Downloading, Installing, and Running the Chemical Reactivity Worksheet (CRW)

  92. A baseline for Pressure Vessel Safety in the USA

  93. ASSE Safety 2016 - Line Break Presentation

  94. PSM/RMP Application and NFPA 704 Ratings

  95. UPDATE on OSHA's PSM Revisions (June 2016)

  96. Congress meddling in PSM and OSHA Outreach Courses again

  97. CAL-OSHA shares details on NH3 HOT Gas/Oil Draining Valve Error Fatality

  98. HI-OSHA gives Federal OSHA PSM Inspection duties

  99. How did you "Class" your PSM/RMP covered process piping?

  100. Did you ever think about the information collection requirements in the PSM Standard?

  101. OR-OSHA announce PSM Inspection Selection Protocol (VPP Sites exempted)

  102. NH3 Fatality - Process Opening/Line Break Gone Bad!

  103. OSHA PSM Letter – Agricultural Retailers Association, et al. v. United States Department of Labor

  104. OSHA's behind the scenes political battle with PSM enforcement

  105. OSHA issue Enforcement Policy Memo to Regional Administrators on "RAGAGEP in Process Safety Management Enforcement"

  106. OSHA Clarifies the Flammable Atmospheric Storage Tank PSM Exemption and why they seek to change it

  107. Process Safety Management SER Background Document (May 2016)

  108. Process Safety Management Small Business Regulatory Enforcement Fairness Act (SBREFA)SER Background Document (May 2016)

  109. UPDATE on OSHA's PSM Revisions (May 2016)

  110. Pressure Differential Between Safety or Safety Relief Valve Setting and Pressure Vessel Operating Pressure (NBIC)

  111. How strong is your MI "Quality Assurance Program"?

  112. Intrinsically SAFE instrumentation MATTERS (digital pressure gauge caused explosion that severed arm)

  113. An OSHA PSM or an EPA RMP inspection is NOT a 3-year audit

  114. What does 527 CMR 33.00: Hazardous Material Process or Processing have to do with the Boston NH3 Fatality?

  115. A functioning weak roof-to-shell seam on Diesel Tank (Hot Work Fire Video)

  116. Using a pressure vessel that does NOT carry the ASME Stamp in the state of CA?
  117. 1998 BLEVE Aniversary
  118. A part of process safety history ending this week (70 ton CL2 release)
  119. Proud moment for SAFTENG
  120. OSHA's GDC for Nitrogen Pressure Vessel Manifold Failure Fatality
  121. Pipe flanges, screwed connections, fittings, valves, meters, etc. and our Hazardous Locations
  122. Inside look at OSHA's desired PSM revisions
  123. Cost–Benefit Analysis of Proposed California Oil and Gas Refinery Regulations (RAND Corp)
  124. How safe is your Permit-to-Work management system? (QRA Results)
  125. Low Pressure storage tank @ brewery catastrophically fails (RD installed upside down)
  126. Crocker Park Propane Tank BLEVE (Update #4 03/14/16)
  127. EPA releases Q&A's on Proposed Changes to the RMP Rule
  128. Free PSM Workshop on April 29, 2016 (WA-OSHA, officially called Department of Labor and Industries )
  129. What is the REQUIRED FREQUENCY of my relief valve(s) maintenance
  130. Tying your Maximum Intended Inventory back to your material and energy balances
  131. A sneak peek @ EPA's Revised RMP Rule (the NPRM)
  132. OMB approves EPA's NPRM on the Risk Management Plan revisions (Modernization of the Accidental Release Prevention Regulations Under Clean Air Act)
  133. FM Global offers FREE GUIDANCE on implementing a "car seal" program
  134. The power of a vacuum (Videos w/ Railcar and Tank Truck)
  135. OSHA requesting permission to inspect "small businesses" who have PSM covered processes
  136. Did a terrorist group and anhydrous ammonia just validate DHS's CFATS?
  137. Does your PSM/RMP utilize “check valves” as a safe guard to PRVENT “reverse flow”?
  138. Defining our Safety Systems in our PSI
  139. HAZLOC's and "Fitness Bands" (Part II)
  140. HAZLOC's and "Fitness Bands" (Part I)
  141. BEST PRACTICES in Contractor Management (NSC White Paper)
  142. ASME BPV Manufacturers' Data Reports On-Line Ordering Information
  143. Catastrophic failure of non-coded pressure vessel (Fatal)
  144. Managing your HFO-1234yf BLEVE risk (Part 6)
  145. West, TX Fertilizer Plant Explosion analysis (videos/photos)
  146. OSHA PSM citations @ chemical manufacturer (Flammables & $66K)
  147. Failure of Relief System results in two (2) fatalities (WorkSafeBC)
  148. FRESH AIR intakes for a ventilation system need to be from a source of FRESH AIR!
  149. Butterfly valves and relief valve line isolation
  150. Example of IMPROPER welding on pressure vessel(s)
  151. ASME B31.5 Pressure Testing and Leak Testing Requirements for Ammonia Refrigeration Processes
  152. OSHA's Interim PSM Enforcement Policy (December 23, 2015)
  153. 2015 OSHA PSM activity by Industry Sectors
  154. Process Opening/Line Break Accident due to IMPROPER LOTO (Government of Western Australia)
  155. Risk Management Plan (RMP) Facilities by the numbers (12/2015)
  156. Worked Example of how a Category 1 Flammable Gas process can be DESIGNED so as to NOT be a PSM Covered process
  157. Is “dispersal of inventory” an accepted method to maintain inventories BELOW PSM/RMP Thresholds?
  158. Runaway: Explosion at T2 Laboratories
  159. OSHA's PSM Retail Exemption, Anhydrous Ammonia, and 2016 Omnibus Bill
  160. Anhydrous Ammonia leads RMP 5-year Accident Histories with Injuries
  161. FM Global UPDATES their Hot Work Fire Statistics involving contractors (2013)
  162. A chance to hear the reasoning/rationale behind Cal/OSHA's PROPOSED rules for "PSM @ Refineries"
  163. Excess Flow Valves and the International Fire Code (IFC)
  164. Legal UPDATE on OSHA's interpretation of a "retail facility" 
  165. EPA memorandum to establish EPA policy on the effect of the OSHA's reinterpretation of the "retail exemption"
  166. A Few Good Auditors (as adapted from the movie A Few Good Men by Joe Chandler
  167. Report of Violation Findings for Third Quarter 2015 (NBBI)
  168. Review of accidents involving ammonia (Institute For Systems Engineering And Informatics)
  169. Analysis of Liquid Ammonia Leakage Accidents based on Safety System Engineering Theory
  170. Explosion of a sulphuric acid tank (H2 Explosion - 2009 France)
  171. Analysis of Accidents in Chemical Process Industry and Lessons Learnt
  172. Start-Up Accident - Metal scaffold deck ejected out of cooling tower (PSSR FAILURE)
  173. HAZARD ALERT - FIRST LINE BREAK (WorkSafeNB)
  174. Is your HHC/EHS a “Category M Fluid” (ASME B31.3)?
  175. What is NURF in the PSM World?
  176. Pressure Vessel Failure Study OSHA PSM citations @ refinery (Document Control & $77K)
  177. Is changing the "service" of your pressure vessel a change that requires an MOC?
  178. Do your pressure vessels design meet RAGAGEP requirements for "pressure differential" between set point and operating pressure? (NB-23)
  179. CalARP looking to add a PROGRAM 4 for Refineries
  180. CalARP Regulation DRAFT PROPOSED Amendments for Petroleum Refineries Emergency Response
  181. Chemical Safety Alert: Safer Technology and AlternativesWhat an Ammonia Vessel inspection and their RVs should look like
  182. CFATs Program Statistics as of November 2, 2015
  183. CSB FY 2015 Management Challenges (OIG Report)
  184. Why Excess Flow Valves FAIL
  185. FAQs from OSHA on their REVISED PSM Retail Exemption Policy
  186. NH3 fatality filling nurse tank (Summary Nr: 200513448)
  187. Could HFO-1234yf have a short live span in our car's AC unit?
  188. Pressure Vessel Inspections 101
  189. Gasoline Storage Tank Overfill Explosion (CSB)
  190. Worked Example of Process Safety Information - “Consequences of Deviation”
  191. OSHA extends the compliance deadline for the REVISED PSM "Retail" Exemption (10/20/2015)
  192. Think you have control of your contractors? We may need to think again…
  193. Material and Energy Balance and "change to facilities that affect a covered process"
  194. ASME CODE and NBIC CHANGES 2015 EDITION
  195. What it looks like to go from a Level 2 RMP to a Level 3 RMP Refrigerant
  196. HFO-1234yf and Flame Retardant Clothing (Part 5)
  197. Comparing EPA's RMP Level 2 to Level 3 Programs
  198. What is the real reason for Maximum Intended Inventory?
  199. Difference in PSI Safe Upper/Lower Limits and SOPs Operating Limits
  200. Processing Facilities and PHMSA Jurisdiction (w/OSHA)
  201. Learnings from a catastrophic release of 24,000 pounds of methyl mercaptan
  202. FREE Chemical Reactivity Worksheet (NOAA) and 1910.119(d)(1)(vii)
  203. DHS CFATS - Anhydrous Ammonia Top-Screen extensionA REAL working example of how OSHA's 1% Rule changes everything
  204. MOCs and Technology
  205. DHS CFATS - What needs to be done when a facility is bought or sold?
  206. Deciphering HHC/EHS Concentrations for PSM/RMP Applicability
  207. Consolidating two (2) Risk Management Plans into one (1)
  208. Your RMP and Earthquakes, Floods, Tornadoes and Hurricanes
  209. EXCELLENT short video on IIAR Pipe Labeling for NH3 Refrigeration Refrigerant
  210. HFO-1234yf is a PSM HHC with “special or unique hazards” (Part 4)
  211. Examples of catastrophic failure of NH3 refrigeration vessels caused by stress corrosion cracking (FMCSA)
  212. Is the Refrigerant HFO-1234yf a BLEVE risk? (Part 3)
  213. Dutch BLEVE Study (Department of Multi-Scale Physics, Faculty of Applied Sciences Delft University of Technology
  214. Cal-OSHA PSM citations @ refinery (Flammables & $566K)
  215. EPA RMP citations for "failure to update RMP every five years and §68.15 Management
  216. Process Safety irony of the week
  217. Refrigerant HFO-1234yf is a Flammable "4" in the NFPA 704 Diamond (Part 2)
  218. Refrigerant HFO-1234yf is a PSM Highly Hazardous Chemical (Part 1)
  219. Using Purged and Pressurized Enclosures for Electrical Equipment (Hazardous Locations)
  220. OSHA's PSM Retail Exemption Interim Enforcement Policy
  221. How does OSHA’s revised PSM “retail exemption” policy impact my RMP?
  222. OSHA issue PSM Retail Exemption Interim Enforcement Policy
  223. 2014 Report of Violation Findings on Pressure Vessels and Pressure Relief Devices (NBBI)
  224. National Board's 2015 First Quarter Violation Report (NBBI)
  225. Our contractors and their “subs”
  226. Proposed Regulatory Changes to Improve Oil Refinery Safety (CalEPA)Plant Ageing Study (UK's HSE COMAH )
  227. Will our cars soon be miniature PSM/RMP covered processes due to the “mildly flammable” refrigerant they will contain?
  228. EPA Seeks Input on Modernizing the Risk Management Plan (RMP) Rule
  229. Making the case my PSM/RMP covered process complies with RAGAGEPs (Vessels)
  230. EPA RMP vs. CalARP (CA Accidental Release Program)
  231. OSHA's presentation on RAGAGEP Enforcement from 2015 ASSE
  232. How OSHA’s move to EPA’s “1% rule” for mixtures change at facilities handling OSHA PSM HHC mixtures
  233. What the heck is "partial pressure" and how do I calculate it for my PSM/RMP mixture?
  234. OSHA memo on Process Safety Management of Highly Hazardous Chemicals and Covered Concentrations of Listed Appendix A Chemicals (same as EPA's 1% Rule)
  235. OSHA memo on RAGAGEP in Process Safety Management Enforcement
  236. Another atmospheric tank over-flow incident with a flammable liquid (CSB)
  237. OSHA's presentation on RAGAGEP Enforcement from 2015 ASSE
  238. Example Contractor Work Permit
  239. EO 13650 Actions to Improve Chemical Facility Safety and Security (Working Group Update)
  240. ASSE 2015 Presentation and PSM Inspection Data (2/27/2014 to 3/30/2015)
  241. A Process Hazards Analysis is NOT an “engineering review” - Part II
  242. A Process Hazards Analysis is NOT an “engineering review”
  243. Pipe labeling by way of ASME A13.1
  244. NH3 Line Break accident
  245. FATAL failure of an anhydrous ammonia compressor
  246. Ammonia Line Rupture Kills One Worker, Injuring Two
  247. Chemical Security Program Statistics as of May 1, 2015
  248. OSHRC on PSM, Guarding, and HAZCOM from a Refinery NEP
  249. Is a bollard just a post?
  250. Excess Flow Valves... Installation, Testing and PM requirements
  251. DIR Releases Status Report on Process Safety Management Regulatory Oversight of California's Petroleum Refineries
  252. EPA is getting in the game of issuing citations for NOT doing an MOC on "staffing changes"!
  253. Shock to the System (CSB Video on Hydraulic Shock in Refrigeration)
  254. IL Pressure Vessel Inspection Frequency (DRAFT FM Procedure)
  255. Chemical Security Program Statistics as of March 2, 2015
  256. Interesting look at some RMP Data
  257. Cal ARP Regulation Amendments 2015
  258. Line Break Gone BAD due to IMPROPER LOTO and OSHRC vacates all OSHA citations (not a type-o!)
  259. Do you “certify” your 3-year PSM/RMP compliance audits?
  260. Consider the assumptions made during a PHA Facility Siting Assessment (Pipe Bridges)
  261. RMP Facilities in the United States as of December 2014 (Congressional Research Service)
  262. Region 5 RMP Presentation (one of the best)
  263. Anhydrous Ammonia at Refrigeration Facilities Under Scrutiny by U.S. EPA
  264. A look into what EPA expects in our RMP 3-year audits
  265. MOCs are much like WORD or EXCEL… they can do so much more than we use them for
  266. PSM Battery Limit Scenario w/ gas cylinders stored within the same building w/ NO passive fire barrier separation (OSHA LOI)
  267. RMP Program Level Flowchart (LA-DEQ)
  268. FM Global Data Sheet beat CSB to punch on Hydraulic Fracturing in NH3 Refrigeration Systems
  269. Chemical Security Program Statistics as of January 5, 2015
  270. CFATS Corporate Approach (DHS 1/20/15)
  271. Boiler Operator Attendance EXCEPTION Requirements now mirror a PSM/RMP style management system
  272. Anhydrous Ammonia Safety Bulletin - Five Key Lessons to Prevent Hydraulic Shock (CSB)
  273. Does a facility have an obligation to notify DHS if the facility is closing?
  274. Dual Stamped pressure vessels
  275. Safety systems and their functions in our SOPs
  276. PSM/RMP Refresher Training Frequency is not a 1,094 day vacation from training!
  277. Another MI Lesson to be learned - Tank Integrity
  278. UK’s HSE issues guidance on RBI Maintenance Programs
  279. HHC/EHS UNLOADING reliance on Excess Flow Valves and another lesson on pipe erosion-corrosion
  280. Congress Passes Legislation to Reinforce Protection and Security of Chemical Facilities
  281. ANSI Z49.1:2012 Available for FREE Download (pdf)
  282. Marsh 1974-2013, Large property damage losses in the Hydrocarbon Industry - 23rd Edition
  283. Another MI learning opportunity with regard to corrosion in piping
  284. Interesting PSM/RMP nuggets from the 12/11/14 Senate hearing on EO - IMPROVING CHEMICAL FACILITY SAFETY AND SECURITY
  285. The fundamentals behind “line breaking”
  286. Christmas eve refinery explosion caused by frozen pipe (Technical Safety Authority of Saskatchewan Executive Report)
  287. Joint Full Committee Hearing - Oversight of the Implications of the President’s Executive Order on Improving Chemical Facility and Security Committee
  288. Chemical Security Program Statistics as of November 1, 2014
  289. UK's HSE Human Factors Briefing Notes
  290. Testing for water in your Ammonia Refrigeration Process
  291. Relief Devices and Condensers in NJ
  292. Interesting RV replacement schedule for PV’s holding NH3 in WI
  293. Bench Testing your Relief Valves and IIAR Edit CAL OSHA's PROPOSED PSM Standard for Refineries
  294. OSHA’s revised Injury and Illness Reporting may call for an MOC at PSM/RMP facilities
  295. Hazardous Locations (HAZLOCs) and Medical Devices
  296. Catastrophic failure of Ammonia Cryogenic Storage Tank w/ Ammonia Fire (7 deaths and 57 injured)
  297. How far would you go with the “co-Location” coverage to determine PSM/RMP coverage?
  298. If this looks familiar... well, you may need some help (Cartoon)
  299. Some interesting changes coming to CalARP
  300. What to Expect from a CFATS Authorization Inspection (DHS)
  301. DHS issues ANPRM for CFATS
  302. ANSI K61.1-1999 Updated and is now CGA 2.1-2014
  303. Process Safety and calibrated direct-reading instrument
  304. 10 years of NH3 and CL2 release data (2004-2014)
  305. OSHRC decision on PSM Contractor Training and Work Permits
  306. Purposely Setting a Valve Higher than Nameplate Stamping: Acceptable or Not? (NBBI)
  307. 08/08/14 UPDATE - Anhydrous Ammonia (NH3) Fatality at a NE Co-Op was an UNLOADING ACCIDENT
  308. CA Ice Rink forced to shutdown by local FD because of failure to comply with CalARP
  309. EPA's Risk Management Program (RMP) Request for Information (RFI)
  310. UPDATE on NH3 Fatality... Coroner's Jury Rules on Anhydrous Ammonia Incident
  311. Flammable Liquids process, PSM, MOC and simultaneous flows
  312. API Releases three (3) New Standards
  313. Your RMP "Emergency Contact"
  314. U.S. EPA Risk Management Plan (RMP) Webinars and Training - RMP*eSubmit Webinars
  315. Boiler and Pressure Vessel Report of Violation Findings for First Quarter 2014
  316. Hazards of Hot Work on Vessels/Containers
  317. Just some random thoughts about "Detectors in my header"
  318. Catastrophic Failure of a Liquid N2 Storage Tank - BLOCKED IN scenario (Japan, 8/28/1992)
  319. UK's HSE guidance on failure modes in Refrigeration Processes
  320. SOP annual certifications and 40 CFR Part 68.200 Recordkeeping (RMP)
  321. TX Fertilizer Plant Explosion analysis (videos/photos)
  322. Is your Engine Room capable of withstanding your WCS?
  323. FREE EPA RMP Training for Ammonia in Ag
  324. Does changing a Relief Valve on a “Header/Manifold” require a line break permit at your facility?
  325. RMP*eSUBMIT Users’ Manual 2014 Update
  326. High Pressure Shutdown Switch Fails - Catastrophic Equipment Failure
  327. Using MARPLOT to obtain your 2010 Census data for your 2014 RMP UPDATE
  328. PRESSURE VESSEL GUIDELINES (OSHA 2014)
  329. Flame Resistance Clothing (FRC) program needs
  330. Another "Unload to Wrong Tank" Incident (Nitric Acid into Caustic)
  331. CCPS Interview with OSHA’s Jordan Barab (Video)
  332. PSM versus TCPA (New Jersey Work Environment Council)
  333. What is your EPA Risk Management Plan “Hazard Index”?
  334. Yep, its JUST Anhydrous Ammonia "in Refrigeration" (Part II)
  335. Excellent Advice from a Relief Valve Manufacturer regarding how to go about establishing Safe Upper Limits
  336. OSHA’s Request for Information (RFI) regarding their PSM Standard has CLOSED, but here are the comments
  337. Its all in how you say it... AND its all in how you're heard! How my 12 year old daughter taught me Human Factors
  338. Plant oil filter failure on compressor causes ammonia leak
  339. Impact of oxygen-enriched atmospheres on fire behavior (USFA)
  340. “Our Initial Start-Up Procedure(s) are the same as our Normal Start-up Procedures”... Guess again!
  341. CFATs newest FAQ Questions (Ammonium Nitrate)
  342. OSHA asking for permission to inspect PSM facilities with fewer than 10 employees
  343. Are my Railcars on site covered under RMP? (Sulphur Trioxide and Flammables/ $21,788 w/ $200,000 SEP)
  344. “Have PPE/Respirator Available”…
  345. A look at what RMP Facilities can expect from EPA in 2014
  346. OSWER Risk Management Program Evaluation Scoping Project (EPA’s path forward in determining who should get an RMP inspection)
  347. CAA 112(r) Inspections - What to expect & suggestions from the inspectors
  348. EPA’s Office of Inspector General says Improvements Needed in EPA Training and Oversight for RMP Inspections
  349. Pipeline fails because deteriorated coating, ineffective cathodic protection, and the failure to detect the corrosion because the pipeline was not inspected or tested after 1988
  350. PSM Inspection Data UPDATE
  351. Massachusetts 527 CMR 33.00: Hazardous Materials Process or Processing (UPDATED)
  352. The 2013 National Board Incident Report (Based on 2002-2008 OSHA Data)
  353. Relief Valve (RV) Header vs. Directly to Atmosphere Edit Another example of "Temporary Operations" in Process Safety Edit
  354. Final Refinery Safety Report Calls for Greater Collaboration and Oversight to Protect the Public and Employees (CAL-OSHA)
  355. Another PSM Learning opportunity (Line Break, Safe Work Permit, LOTO, PPE, Pipe Labeling)
  356. Updating your RMP OCA Populations
  357. RISK MANAGEMENT PLAN CO-LOCATION GUIDANCE OF NON-INTERCONNECTED REGULATED SUBSTANCE VESSELS (OH EPA)
  358. Food Processing Company Settles Violations of Chemical Release Reporting Requirements (NH3 Refrigeration)
  359. Process Safety Operating Procedures and a Certified PPE Hazard Assessment
  360. Is your facility REALLY prepared for an emergency? (ERT and PSM SOPs)
  361. Vibration-induced fatigue on process pipework
  362. Are we "dumbing" down RAGAGEPs to make OSHA's job harder?
  363. API provides OPEN/FREE access to many of their codes/practices
  364. How rigorous is your contractor safety evaluation(s)?
  365. Discharging Pressure Vessel RVs back into process
  366. INTERIM CHEMICAL ACCIDENT PREVENTION ADVISORY - Design of LPG Installations at Natural Gas Processing Plants
  367. 2014 Public Listening Session Schedule and Registration Information EO 13650 Improving Chemical Facility Safety and Security
  368. EPA Region X RMP Training
  369. Does PSM/RMP standards need a Ultimate Work Authority and Stop Work Authority concepts?
  370. UPDATE - State of MA Hazardous Material Process or Processing: 527 CMR 33
  371. HAZCOM labeling changes and your PSM/RMP programs
  372. De-Rating or Re-Rating a Pressure Vessel
  373. CSB Draft Report Proposes Overhaul of Refinery Industry Regulatory System in CA and Urges Adoption of the "Safety Case Regime" to Prevent Major Chemical Accidents
  374. Acting Responsibly? Federal Contractors Frequently Put Workers’ Lives and Livelihoods at Risk
  375. ASME's Single Certification Mark (new nameplate)
  376. Training requirements for mechanics repairing and/or testing pressure relief devices
  377. The 12 things OSHA wants to change about it PSM Standard and its enforcement
  378. Hydrofluoric Acid (HF) Fatality (TNOSHA)
  379. CSB follow-up letter to DOT regarding emergency shutdown systems for chlorine railcars
  380. EPA explains the difference between a PHA and a "Hazard Review"
  381. PHMSA answers the question... Who regulates the unloading of ammonia to a process
  382. First (1st) Public Review of Standard BSR/IIAR 2-201x, Safety Standard for Equipment, Design, and Installation of Closed-Circuit Ammonia Mechanical Refrigeration Systems (11/22/13 - 1/6/14)
  383. National Board Report of Violation Findings for Second Quarter 2013
  384. Another example of Catastrophic Pressure Vessel failure
  385. Changes to ANSI K61.1 (Storage and Handling of Anhydrous Ammonia)
  386. Key Process Safety Performance Indicators (UK's HSE)
  387. New Edition of Pamphlet 6, Piping Systems for Dry Chlorine, now AVAILABLE
  388. What could your NH3 38,000 pound WCS look like?
  389. PHA's and "previous incidents"
  390. Pressure Vessel Accident Rates
  391. CATASTROPHIC FAILURE of ASME Pressure Vessel (Video and CSB Investigation)
  392. OSHA is considering revising its Process Safety Management (PSM) standard
  393. First (1st) Public Review of Standard BSR/IIAR 4-201x, Installation of Closed-Circuit Ammonia Mechanical Refrigeration Systems Edit "Temporary Operations" in Ammonia Refrigeration
  394. RMP WCS and "An enclosed space in direct contact with outside air" (UPDATED 11/7/13 w/ EPA Response)
  395. Inside an EPA RMP Inspection at a Refinery
  396. BSEE Releases Panel Investigation Report into Fire and Explosion on Gulf of Mexico Platform (FATAL HOTWORK ACCIDENT)
  397. What is it? Hint: Think piping RAGAGEP
  398. Comparison of Tier II, TRI, and 112(r) Requirements
  399. Which agency (feds, state, county) enforces RMP at your facility?
  400. NBIC Pressure Relief Device (PRD) Inspection Guide
  401. Principles for proof testing of safety instrumented systems in the chemical industry (UK's HSE)
  402. RMP and Population Estimates from 2010 Census Data
  403. Challenging PHA assumptions during revalidation
  404. NH3 Refrigeration Auto Purger Design Change
  405. 3" NH3 Pipe Failure (video)
  406. Control Room Management and Human Factors
  407. PHAs and the consequences of engineering and administrative controls failing
  408. Chemical Advisory: Safe Storage, Handling, and Management of Ammonium Nitrate
  409. What is a "Tell-Tale" gauge and why is it significant in process safety
  410. Pipe RAGAGEPs and Hydrostatic relief
  411. Is the 1-U form for my pressure vessel really not a PSM requirement?
  412. OSHRC frowns on OSHA's use of "Internal Reports/Documents" to issue PSM citations
  413. What do I have to do for material and energy balances?
  414. Run to failure... Can it be done while achieving process safety?
  415. The National Board of Boiler and Pressure Vessel Inspectors Report of Violation Findings for First Quarter 2013
  416. Looking for some technical data for one of your pressure vessels?
  417. CFATs Program Statistics as of August 1, 2013
  418. How can I determine if my facility’s wastewater treatment operation meets the Chemical Facility Anti- Terrorism Standards (CFATS) exemption under 6 CFR 27.110(b) for the Federal Water Pollution Control Act?
  419. "It's just Ammonia" - yep it sure is!
  420. Executive Order - Improving Chemical Facility Safety and Security
  421. Passivation... PSM/RMP activity that belongs in the "initial start-up" SOP?
  422. Making the case my PSM/RMP covered process complies with RAGAGEPs (Piping)
  423. Emergency Response Program (ERP) requirements differ for PSM and RMP
  424. Control the amount of scaffolding permitted in a process area?
  425. The RAND Corporation memo for the CA-OSHA Process Safety Review
  426. Draft Report of the Interagency Working Group on Refinery Safety - Improving Public and Worker Safety at Oil Refineries
  427. PHMSA Safety Advisory - Heating Railcars
  428. EPA Region 10 Top 5 RMP violations
  429. Seven Keys to Surviving a Chem NEP Audit (John Newquist)
  430. Hansen RV's - URGENT PRODUCT SAFETY NOTICE IMMEDIATE ACTION REQUIRED
  431. OSHA reaches settlement agreement with Food Company to protect workers from NH3
  432. Answering the question... Can a Relief Valve be installed horizontally?
  433. RAGAGEPs and "the numbers"
  434. DHS CFATS Update as of June 6, 2013
  435. Human and organizational errors are the major cause of equipment failures in in the process industries
  436. Ammonia Incidents in NY State
  437. Ammonia Refrigeration FATALITY - Compressor Pump Out Valve
  438. Runaway reaction fatality explosion (TNOSHA)
  439. Line Break Fatality @ Refinery (TNOSHA)
  440. Ammonia Refrigeration FATALITY - Chiller Valve
  441. Boiler & Pressure Vessel accidents by year (from NBIC)
  442. What ISA-84 can do for process safety
  443. Considering failure of engineering controls in a PHA
  444. National Board Inspection Code vs. API 510
  445. Process Safety and Hotwork requirements
  446. Techniques for assigning a Target Safety Integrity Level (SIL)
  447. Understanding ISA-84
  448. EPA RMP Q&A on latitude and longitude coordinates (April 2011)
  449. FREE CCPS Reactivity Management Tool (RMT)
  450. June 2012 CCPS Process Beacon - Nitrogen – Hazard and Safeguard!
  451. Ammonia Explosion News Accounts
  452. EPA announces summary of enforcement actions for Winter 2012
  453. Does your PSM/RMP included power systems?
  454. DHS completes the 1000th Compliance Assistance Visit (CAV)
  455. FREE COPY of Z49.1:2012 Safety in Welding, Cutting, and Allied Processes
  456. Anhydrous Ammonia Tank Catastrophic Failure
  457. Relief Valve Maintenance & Testing
  458. Relief Valve sizing and combustible/flammable storage
  459. Has PSM driven us to dilute some “engineering standards”?
  460. Pressure Vessels, MDMT, and Auto-Refrigeration (NBBI)
  461. Implementation of New ASME Stamp for Pressure Relief Devices
  462. Bypassing of storage tank safety features
  463. Compliant with RAGAGEP?
  464. May 2012 CCPS Process Beacon - Mechanical Integrity of Tubing
  465. Are we overdoing procedures?
  466. UK's HSE REVIEW OF CHLORINE INCIDENTS 1992 - 1998
  467. MAJOR CHEMICAL DISASTERS IN INDIA
  468. Ammonia Incidents in Oregon from 1993-2007
  469. Workplace Health and Safety Queensland - Ammonia National Audit Program results
  470. UK's HSE REVIEW OF AMMONIA INCIDENTS 1992 - 1998
  471. 2012 April CCPS Process Beacon - Unloading to the wrong tank
  472. Using the common practice of “Draining Oil Pots” on refrigeration systems to examine the differences between “controlled” and “uncontrolled” releases of ammonia
  473. An interesting "Facility Change" that fell through the cracks
  474. The finer points of OSHA’s and EPA’s Management of Change requirements
  475. EPA cancels their July 2012 Public Access to RMPs
  476. Taking credit for a building in a WCS under RMP
  477. Stairs vs. Ladders and Emergency Egress
  478. March 2012 Update on OSHA’s Refinery & Chemical National Emphasis Programs
  479. Does your facility “Car Seal” or “Lock Open” Valves? Do NOT use your LOTO Locks!
  480. A close look at Incident Investigation techniques A MUST READ for ALL Safety Pro's
  481. Ammonia HAZARD ALERT issued by NC-OSHA in response to a fatal accident involving NH3
  482. Annual SOP Certifications for PSM/RMP
  483. VPP Application Supplement for the Sites Subject to the Process Safety Management (PSM) Standard
  484. Temporary MOC’s and Temporary Electrical Power
  485. Ammonia and HAZLOC's (join the debate)
  486. DHS Jack Rabbit CL2 and NH3 Release Testing presentation video (NO video of releases)
  487. Why would my NH3 ventilation discharge need to be a Hazardous Location? Unpublished
  488. Mechanical Ventilation - General Rules to live by
  489. The IMPORTANCE of Hydrostatic relief valves in Ammonia Systems
  490. RMP and Transportation Containers
  491. RMP Program Level Determination Flowchart
  492. Summary of the RMP Chemical Exemptions
  493. 2012 March CCPS Process Beacon - Double Block & Bleed Explanation
  494. Difference between OSHA’s PSM and EPA’s RMP requirements
  495. Comparison of RMP and PSM Chemicals and Thresholds
  496. State of Massachusetts Hazardous Materials Processing regulation (527 CMR 33)
  497. Challenging the NH3 Refrigeration & Electrical Classification (UPDATED 3/3/12)
  498. Is the act of loading/unloading a PSM/RMP chemical exempt from OSHA/EPA enforcement?
  499. Changing your RMP Emergency Contact
  500. Can a PHA done for OSHA's PSM be used for EPA's RMP Compliance?
  501. A reverse look at Facility Siting and Change Management
  502. How many threads of a bolt must be showing outside a nut to meet RAGAGEP?
  503. Hotwork - Learning from Losses
  504. Change(s) that REQUIRE a PHA revalidation AND RMP Update
  505. Interesting RMP Statistics - Where does your process rank?
  506. PSM Scenario Challenge - Response
  507. Hotwork Safety
  508. The advantage of utilizing a Contractor Work Permit
  509. Ammonia Gas Explosion
  510. Use of High Visibility Vest in Safety Programs
  511. Refinery NEP UPDATE (12/5/07)
  512. NFPA 30 offers some GREAT facility siting for NEW process vessels
  513. Process Hazards Analysis and “Safeguards”
  514. “Operator Rounds” in a PSM/RMP Covered Process
  515. NH3 Unloading Incident (30 Tons Release)
  516. AMMONIA SPILLS IN WISCONSIN 1993-2009
  517. The power of a vacuum (photo)
  518. Establishing your safe upper and lower limits for FLOWS
  519. Establishing Safe Upper and Lower Limits
  520. Key provisions of the PSM Preamble
  521. Tracking Corrective Actions to closure
  522. PSM, Flammable Liquids, & Secondary Containment
  523. Current EPA plans call for the re-establishment of internet access to the non Off-site Consequence Analysis (OCA) sections of the RMP database beginning in July of 2012
  524. OSHA Launches their PSM Covered Chemical Facilities NEP
  525. The Borden's Ammonia Explosion December 11, 1983
  526. Flammable Liquids Tank Integrity Learnings
  527. Features of successful Safety Management System (SMS)
  528. Importance of MAINTAINING your Explosion Proof Equipment (Video)
  529. PHA and Loss of Power
  530. OSHA's Pressure Vessel "Cheat Sheet"
  531. The Jack Rabbit Test Program Trial Summary - NH3 and CL2 Release Studies
  532. PSM Battery Limits - it may not be as simple as "Interconnected"
  533. More OSHA PSM Citations on a NH3 Refrigeration Process (includes NO MOC on personnel changes!)
  534. Explosion of MDEA Storage Tank
  535. How strong does my explosion have to be to do damage?
  536. Another valve that needs to be Car-Sealed OPEN
  537. Vulnerability of oil contaminated fire retardant coveralls
  538. Contractors and chemical process safety?
  539. Electrical Classification for Hazardous Locations
  540. How secure are your safety systems?
  541. PSM Coverage and the Meer decision Unpublished
  542. Management of Change (MOC) and Procedures
  543. Is EPA setting a standard for PSM/RMP Staffing Levels?
  544. Anhydrous Ammonia Stress Corrosion Cracking (SCC) Incident sends 5 to hospital
  545. Animation of January 23, 2010 Phosgene Accident
  546. CFATS Personnel Surety Privacy Impact Assessment is now available
  547. Truck Drivers being your DOT HAZMAT Attendant and potential safety and health concerns
  548. What does EPA's RMP "General Duty Clause" actually require?
  549. Buyer BEWARE regarding offsite Operator and Maintenance training courses
  550. Process Safety and Security Guards
  551. HOTWORK Tank Explosion (Video)
  552. PSM Chemical Plant NEP UPDATE March 2011
  553. Replacement in Kind... is it really?
  554. PSM/RMP "co-location" or "proximity" when determining PSM/RMP Applicability
  555. Worst Case Release Scenario and Severe Weather
  556. EPA's RMP and Program 3 NAICS #'s
  557. RMP*eSubmit Webinar Presentation
  558. THE REAL COST of an accident!
  559. A perfect storm in the making...have we learned our lesson?
  560. RMP eSubmit Webinar Questions and Answers
  561. RMP Worst Case Scenario considerations
  562. Another Example of Torque Requirements - GASKETS
  563. Torque Examples - Mechanical-Joint Assembly
  564. Torque Requirements and Process Safety Management
  565. Fire Watches and their Fire Extinguishers
  566. PSM and Electronic Management Systems and Emergency Power Systems
  567. Is Your Welding Hot Work Policy in Compliance (VIDEO - 5 minutes)
  568. Dangers of Hot Work - VIDEO (14 Min)
  569. Maintain Process Safety During the Recession (Video)
  570. Is your Fire Extinguisher Contractor covered under PSM?
  571. Ammonia HAZARD ALERT issued by NC-OSHA in response to a fatal accident involving NH3
  572. New Leading and Lagging Indicators of Process Safety Performance
  573. When is Flame Retardant Clothing (FRC) Really required?
  574. PSM Operating Procedures Survey Conducted
  575. Is OSHA Targeting Ammonia Refrigeration & Chlorine water treatment processes in their new PSM NEP?
  576. States with RMP accidents causing at least one off-site Death
  577. EPA's General Duty Clause for RMP
  578. More on EPA's General Duty Clause
  579. Top 10 RMP Chemicals by On-Site Quantities
  580. Refinery Heat Exchanger Failure Fatality
  581. Concurrent Operating Procedures…Emergency Shutdown and Start-Up after ESD
  582. Some GREAT PHA Observations from one of the best in the business
  583. Some GREAT Process Safety Observations from one of the best in the business
  584. How do you define a PSM/RMP contractor and what does your evaluation process look like?
  585. NH3 Releases occurring in NY state from 1993-98
  586. Difference in Emergency SOPs and Emergency Response Plan
  587. Unloading Hoses and PSM/RMP
  588. IMPORTANT NOTICE regarding NH3 and LPG hoses
  589. Hot Work Requirements and Combustible Dusts
  590. Hot Work Preparation and OSHA Requirements
  591. Hot Work Safety and learning from others costly errors
  592. Better be thinking MOC before you do RBI
  593. Mechanical integrity management of bulk storage tanks
  594. Trick Question or legit question for PSM Compliance? Contractor Evaluations and PRCS Rescue Evaluations
  595. What are "Temporary Operations" in regards to PSM Operating Procedures 1910.119(f)(1)(i)(C)
  596. The difference between a MOC and PSSR
  597. Staffing and Management of Change
  598. What is a RAGAGEP?...and what it is NOT
  599. Ventilation...Can I use it to declassify a HAZLOC?
  600. Missed Preventive Maintenance Inspections/Tests
  601. Emergency Shutdown (when does it get activated)
  602. Car Seal Program and Relief Valves
  603. How to use your PHA to write your SOPs
  604. Starting point for PSM Facility Siting when dealing with Flammables (updated with LPG on 8/12/12)
  605. Is your Diking in your PSI and MI
  606. Tips when performing PHA's and how Chemical Process Safety should be viewed
  607. Buying a used PSM/RMP facility or used equipment for PSM/RMP
  608. Report reveals fundamental management flaws lay behind Buncefield disaster
  609. UPDATE on Chemical Facility Anti-Terrorism Standards (CFATS)
  610. CSB Releases Case Study on Fatal 2008 Accident at a Tire and Rubber Plant
  611. Car-Seal Programs and how they operate
  612. Flaw in NH3 Emergency Ventilation Design?
  613. Managing your Relief Valves
  614. "Lessons Learned" potentials from Japan's Nuclear Problems
  615. Liquid Penetrant Examination (NBBI)
  616. Guidance for Conducting Risk Management Program Inspections under Clean Air Act Section 112(r)
  617. LOPA and SIS/SIL
  618. Valves installed backwards?
  619. 2010 SECTION VIII — DIVISION 1 NON-MANDATORY APPENDIX M - INSTALLATION AND OPERATION
  620. Post Weld Heat Treating (PWHT) failure
  621. Management of Organizational Change (OSHA Letter to RAs)
  622. EPA Can Improve Implementation of the Risk Management Program for Airborne Chemical Releases (EPA OFFICE OF INSPECTOR GENERAL)
  623. Process Hazards Analysis Techniques (Methodologies, Resources, and Time)
  624. Rupture Disc between Pressure Vessel and Relief Valve (and after the RV)
  625. Catastrophic Failure during pneumatic pressure test
  626. Brittle Fracture (Catastrophic) Failure during HYDROTEST of Propane Bullet
  627. What does "relief system design basis" mean?
  628. Cellular Phones and Other Risks in Classified Areas
  629. The BASICS on PRESSURE VESSEL SAFETY (OSHA)
  630. 5,700-gallon hydrochloric acid (HCl) storage tank ruptured during filling
  631. What differentiates a GREAT PSM/RMP audit from a "so-so" audit?
  632. What is LUP & PADHI and what does it have to do with West Fertilizer?
  633. How many Program 2 RMPs like West Fertilizer are out here?
  634. West, TX Fertilizer... a lesson in "process safety" and the "retail facility" exemption?
  635. Animation of Fire at Chevron's Richmond Refinery, August 6, 2012
  636. How could the TX fertilizer plant be a Program 2 RMP?
  637. Hydrogen Fluoride Study, Report to Congress Section 112(n)(6) Clean Air Act As Amended
  638. Nonsparking Tools (USFA)
  639. Emergency Shutdown Systems and Hydrostatic Relief Valves
  640. OSHA's "hydrocarbon fuel exemption” in PSM
  641. Facility Siting 101 - Vehicle Barriers around critical equipment (NH3 Tank Damage from Semi - Photos/Layout/RMP)
  642. What are the requirements when a component in my covered process was built to an OLD "out of circulation" RAGAGEP?
  643. The CSB and API appear to be at odds on Recommended Practice ANSI/RPI 755, Fatigue Risk Management Systems for Personnel in the Refining and Petrochemical Industries, First Edition, April 2010
  644. Splitting the hairs of Process Safety (Battery Limits and Changes)
  645. Potential Issues When Wearing Non-Fire Resistant Base Layers with Outerwear Fire-Resistant Garments
  646. Guidance on Handling Cases Developed Pursuant to the FRC Enforcement Policy Memorandum
  647. Transport Company indicted in SC woman's ammonia death (Unloading NH3)
  648. PSM/RMP Trick Question (Poll)
  649. A "Manufacturer's Recommended Practice" is a RAGAGEP
  650. HAZLOCs and Ventilation and Classification
  651. A flaw with referencing info in PSM/RMP Operating Procedures
  652. Understanding the requirements of Standard Operating Procedures (SOP)
  653. OUTSTANDING Process Safety Information Worksheet
  654. Evaluating your Mechanical Integrity Program effectiveness Edit Inside look at EPA's Ammonia Alarm Expectations Edit Pressure Vessel Update (NB-132, Revision 8)
  655. OSHA's "Process Opening" Hazard Information Bulletin
  656. Unloading HAZMATs and PSM/RMP
  657. Catastrophic failure of RRCar while being steamed (Excess temp leads to exotherm runaway)
  658. Cargo Hose Rupture and Release of Anhydrous Ammonia During Offloading of a Cargo Tank Motor Vehicle at a Plant (7/15/09)
  659. Do NOT rely on Excess Flow Valves (EFV)
  660. Can I count the activation of my safety system as an actual test of the system?
  661. UPDATE: CCTV video of the Mexico Refinery Explosion on 9/19/12
  662. Sulphur sticks and ammonia leaks... are you in compliance when using these leak detection devices?
  663. Hotwork Safety (UPDATED w/ NEW Hotwork data 12/04/12)
  664. ASME UG-140... Overpressure protection by System Design
  665. What does ASME Section VIII say about "torquing values"?
  666. Can a spring-loaded Pressure Safety Valve be installed horizontially?
  667. OSHA issues PSM citations after run-away reaction results in the hospitalization of 40 workers
  668. OSHA issues PSM, HAZCOM, Asbestos, BBP, Fire Extinguishers, Walking/Working, Ladders, Guarding, Electrical, GDC, Hotwork,
  669. Hydrostatic Relief Valves and Propane Systems
  670. ASME "Lethal Service"
  671. Third Public Review of Standard BSR/IIAR 7-201x, Developing Operating Procedures for Closed-Circuit Ammonia Mechanical Refrigerating Systems
  672. Sixth Public Review of Standard BSR/IIAR 5-201x, Start-up and Commissioning of Closed-Circuit Ammonia Mechanical Refrigerating Systems
  673. Internal Combustion Engines as Ignition Sources
  674. Evaluation of Health Effects of a Chlorine Gas Release in a Poultry Processing Plant - Arkansas
  675. RMP reporting requirements, when to update, and how to submit using the new web-based system
  676. RMP's “Stationary Source” and "Incident to Transportation" exemption challenged
  677. EPA to audit the CSB????
  678. PSM Information Collection Requirements
  679. The infamous "Process Safety Contractor Safety Study" by the John Gray Institute
  680. Phillips 66 Explosion & Fire - Pasadena, TX 1989
  681. Non-Routine process opening (e.g. "Line Break")
  682. EPA Region X's RMP "Management Plan" Example
  683. A OSHRC review of PSM Citations following a 32,000 pound release (NH3 Refrigeration)
  684. Preliminary fire testing of composite offshore pedestrian gratings
  685. Perfect example of using the "Elimination/Substitution" in the hierarchy of controls as well as IST
  686. Keep'n it real during the Process Hazards Analysis Unpublished
  687. Some hazards deserve all four levels of controls! Unpublished
  688. One of the worst refrigeration accidents rarely mentioned! (2007)
  689. What is it? (Hint: Common PSM Safe Guard)
  690. National Board RV Testing Data
  691. RMP Facilities in the United States as of December 2009
  692. Re-Submitting your RMP
  693. Putting Seward, IL 38,000 NH3 release into some perspective
  694. Can Stress Corrosion Cracking (SCC) occur in Ammonia Piping?
  695. Flixborough... the beginning of the PSM movement
  696. VIDEO UPDATE on Fatal HF Release - 5 Dead 18 Injured
  697. Ohio Fire Code Requirements for Mechanical Refrigeration facilities using Ammonia
  698. OSHA Enforcement Memo - Use of Flexible Hoses in Toxic Gas Service (10/2/2012)
  699. Ohio's PSM/RMP General Duty Clause
  700. Process Safety and Ohio State Fire & HAZMAT Codes
  701. Applications and Limitations of Excess Flow Valves
  702. Ammonia Releases in North Carolina (1993-1997 Data)
  703. Loss of Containment (LOC) Data
  704. Liquefied Gas Conversion Chart
  705. When we claim alarms as "safe guards" in our PHA
  706. TOSHA cites Refinery $63,000 for Fatal Flash Fire (PSM, LOTO, PPE)
  707. EPA Region 10 RMP Newsletter- great resource!
  708. Ammonia Fatality @ Winery
  709. Amuay UCVE Event Aug 25, 2012
  710. Process Safety and "Human Factors" (w/ video)
  711. CCTV Video & photos from Chevron's Richmond, CA refinery fire
  712. OSHA issues PSM citations to a TX Refinery
  713. How does OSHA and EPA define "retail establishment" in regards to their "exemptions" from PSM/RMP
  714. OSHA issues PSM, Explosives, PPE, Machine Guarding, LOTO, Electrical, and Flammable Liquid citations after explosion at a fireworks plant
  715. Stress Corrosion Cracking of Steel in Liquefied Ammonia Service - A Recapitulation
  716. Corrosion Rates and Remaining Life/Fitness for Service
  717. Comparison of Piping Inspection Requirements in Refrigeration Industry
  718. Comparison of Pressure Vessel Inspection Requirements in Refrigeration Industry
  719. Hydrostatic Relief Devices vs. Qualified Operator, which is required?
  720. Auditing Process Safety Management Systems
  721. OSHA issues $111K in PSM Citations following explosion that severely injured worker (PSM)
  722. Flixborough Explosion (1974)
  723. (8/25/12 UPDATE from DOT) IMPORTANT NOTICE REGARDING (NH3) AND (LPG) HOSES
  724. Risks associated with Loading and Unloading HAZMAT
  725. ANSI/ASME B31 - Standards of Pressure Piping
  726. The 12 sections of the Boiler Pressure Vessel Code (BPVC)
  727. EPA fines the US Olympic Park for RMP violations related to their Anhydrous Ammonia refrigeration process
  728. OR-OSHA changes their PSM applicability to NH3 Fertilizer and the impact it will have on RMP
  729. EPA Region X RMP/EPCRA Actions April 1-June 30, 2012
  730. Process Safety and “Critical Utilities”
  731. Has EPA established a new selection criteria for RMP inspections?
  732. MI Inspection of Anhydrous Ammonia Vessel (No PWHT)
  733. Now this is Process Safety Information!!
  734. August 2012 CCPS Process Beacon - HOTWORK HAZARDS
  735. Flammable vapour cloud risks from tank overfilling incidents
  736. Excellent depiction of PSM/RMP Process Arrangements
  737. Another "Culture" Failure leads to major pipeline incident
  738. Inherently Safer Design (CSB Video)
  739. Process Safety, Staffing, and responding to alarms
  740. PSM Enforcement UPDATE from Region V
  741. A NON-PSM chemical impacting a PSM covered process
  742. WA-OSHA latest State Plan to implement PSM CHEM NEP
  743. “LOPC” of an ammonia pipe in unoccupied refrigerated spaces
  744. Culpeper, Va. settles alleged environmental violations at water treatment facility (RMP-Chlorine)
  745. Flammable Liquid and Gas PSM Citations
  746. What ISA-84 can do for process safety
  747. Considering failure of engineering controls in a PHA
  748. National Board Inspection Code vs. API 510
  749. Process Safety and Hotwork requirements
  750. Techniques for assigning a Target Safety Integrity Level (SIL)
  751. Understanding ISA-84
  752. EPA RMP Q&A on latitude and longitude coordinates (April 2011)
  753. FREE CCPS Reactivity Management Tool (RMT)
  754. June 2012 CCPS Process Beacon - Nitrogen – Hazard and Safeguard!
  755. Ammonia Explosion News Accounts
  756. EPA announces summary of enforcement actions for Winter 2012
  757. Does your PSM/RMP included power systems?
  758. DHS completes the 1000th Compliance Assistance Visit (CAV)
  759. FREE COPY of Z49.1:2012 Safety in Welding, Cutting, and Allied Processes
  760. Anhydrous Ammonia Tank Catastrophic Failure
  761. Relief Valve Maintenance & Testing
  762. Relief Valve sizing and combustible/flammable storage
  763. Has PSM driven us to dilute some “engineering standards”?
  764. Pressure Vessels, MDMT, and Auto-Refrigeration (NBBI)
  765. Implementation of New ASME Stamp for Pressure Relief Devices
  766. Bypassing of storage tank safety features
  767. Compliant with RAGAGEP?
  768. May 2012 CCPS Process Beacon - Mechanical Integrity of Tubing
  769. Are we overdoing procedures?
  770. UK's HSE REVIEW OF CHLORINE INCIDENTS 1992 - 1998
  771. MAJOR CHEMICAL DISASTERS IN INDIA
  772. Ammonia Incidents in Oregon from 1993-2007
  773. Workplace Health and Safety Queensland - Ammonia National Audit Program results
  774. UK's HSE REVIEW OF AMMONIA INCIDENTS 1992 - 1998
  775. 2012 April CCPS Process Beacon - Unloading to the wrong tank
  776. Using the common practice of “Draining Oil Pots” on refrigeration systems to examine the differences between “controlled” and “uncontrolled” releases of ammonia
  777. An interesting "Facility Change" that fell through the cracks
  778. The finer points of OSHA’s and EPA’s Management of Change requirements
  779. EPA cancels their July 2012 Public Access to RMPs
  780. Taking credit for a building in a WCS under RMP
  781. Stairs vs. Ladders and Emergency Egress
  782. March 2012 Update on OSHA’s Refinery & Chemical National Emphasis Programs
  783. Does your facility “Car Seal” or “Lock Open” Valves? Do NOT use your LOTO Locks!
  784. A close look at Incident Investigation techniques A MUST READ for ALL Safety Pro's
  785. Ammonia HAZARD ALERT issued by NC-OSHA in response to a fatal accident involving NH3
  786. Annual SOP Certifications for PSM/RMP
  787. VPP Application Supplement for the Sites Subject to the Process Safety Management (PSM) Standard
  788. Temporary MOC’s and Temporary Electrical Power
  789. Ammonia and HAZLOC's (join the debate)
  790. DHS Jack Rabbit CL2 and NH3 Release Testing presentation video (NO video of releases)
  791. Why would my NH3 ventilation discharge need to be a Hazardous Location? Unpublished
  792. Mechanical Ventilation - General Rules to live by
  793. The IMPORTANCE of Hydrostatic relief valves in Ammonia Systems
  794. RMP and Transportation Containers
  795. RMP Program Level Determination Flowchart
  796. Summary of the RMP Chemical Exemptions
  797. 2012 March CCPS Process Beacon - Double Block & Bleed Explanation
  798. Difference between OSHA’s PSM and EPA’s RMP requirements
  799. Comparison of RMP and PSM Chemicals and Thresholds
  800. State of Massachusetts Hazardous Materials Processing regulation (527 CMR 33)
  801. Challenging the NH3 Refrigeration & Electrical Classification (UPDATED 3/3/12)
  802. Is the act of loading/unloading a PSM/RMP chemical exempt from OSHA/EPA enforcement?
  803. Changing your RMP Emergency Contact
  804. Can a PHA done for OSHA's PSM be used for EPA's RMP Compliance?
  805. A reverse look at Facility Siting and Change Management
  806. How many threads of a bolt must be showing outside a nut to meet RAGAGEP?
  807. Hotwork - Learning from Losses
  808. Change(s) that REQUIRE a PHA revalidation AND RMP Update
  809. Interesting RMP Statistics - Where does your process rank?
  810. PSM Scenario Challenge - Response
  811. Hotwork Safety
  812. The advantage of utilizing a Contractor Work Permit
  813. Ammonia Gas Explosion
  814. Use of High Visibility Vest in Safety Programs
  815. Refinery NEP UPDATE (12/5/07)
  816. NFPA 30 offers some GREAT facility siting for NEW process vessels
  817. Process Hazards Analysis and “Safeguards”
  818. “Operator Rounds” in a PSM/RMP Covered Process
  819. NH3 Unloading Incident (30 Tons Release)
  820. AMMONIA SPILLS IN WISCONSIN 1993-2009
  821. The power of a vacuum (photo)
  822. Establishing your safe upper and lower limits for FLOWS
  823. Establishing Safe Upper and Lower Limits
  824. Key provisions of the PSM Preamble
  825. Tracking Corrective Actions to closure
  826. PSM, Flammable Liquids, & Secondary Containment
  827. Current EPA plans call for the re-establishment of internet access to the non Off-site Consequence Analysis (OCA) sections of the RMP database beginning in July of 2012
  828. OSHA Launches their PSM Covered Chemical Facilities NEP
  829. The Borden's Ammonia Explosion December 11, 1983
  830. Flammable Liquids Tank Integrity Learnings
  831. Features of successful Safety Management System (SMS)
  832. Importance of MAINTAINING your Explosion Proof Equipment (Video)
  833. PHA and Loss of Power
  834. OSHA's Pressure Vessel "Cheat Sheet"
  835. The Jack Rabbit Test Program Trial Summary - NH3 and CL2 Release Studies
  836. PSM Battery Limits - it may not be as simple as "Interconnected"
  837. More OSHA PSM Citations on a NH3 Refrigeration Process (includes NO MOC on personnel changes!)
  838. Explosion of MDEA Storage Tank
  839. How strong does my explosion have to be to do damage?
  840. Another valve that needs to be Car-Sealed OPEN
  841. Vulnerability of oil contaminated fire retardant coveralls
  842. Contractors and chemical process safety?
  843. Electrical Classification for Hazardous Locations
  844. How secure are your safety systems?
  845. PSM Coverage and the Meer decision Unpublished
  846. Management of Change (MOC) and Procedures
  847. Is EPA setting a standard for PSM/RMP Staffing Levels?
  848. Anhydrous Ammonia Stress Corrosion Cracking (SCC) Incident sends 5 to hospital
  849. Animation of January 23, 2010 Phosgene Accident
  850. CFATS Personnel Surety Privacy Impact Assessment is now available
  851. Truck Drivers being your DOT HAZMAT Attendant and potential safety and health concerns
  852. What does EPA's RMP "General Duty Clause" actually require?
  853. Buyer BEWARE regarding offsite Operator and Maintenance training courses
  854. Process Safety and Security Guards
  855. HOTWORK Tank Explosion (Video)
  856. PSM Chemical Plant NEP UPDATE March 2011
  857. Replacement in Kind... is it really?
  858. PSM/RMP "co-location" or "proximity" when determining PSM/RMP Applicability
  859. Worst Case Release Scenario and Severe Weather
  860. RMP*eSubmit Webinar Presentation
  861. THE REAL COST of an accident!
  862. A perfect storm in the making...have we learned our lesson?
  863. RMP eSubmit Webinar Questions and Answers
  864. RMP Worst Case Scenario considerations
  865. Another Example of Torque Requirements - GASKETS
  866. Torque Examples - Mechanical-Joint Assembly
  867. Torque Requirements and Process Safety Management
  868. Fire Watches and their Fire Extinguishers
  869. PSM and Electronic Management Systems and Emergency Power Systems
  870. Is Your Welding Hot Work Policy in Compliance (VIDEO - 5 minutes)
  871. Dangers of Hot Work - VIDEO (14 Min)
  872. Maintain Process Safety During the Recession (Video)
  873. Is your Fire Extinguisher Contractor covered under PSM?
  874. Ammonia HAZARD ALERT issued by NC-OSHA in response to a fatal accident involving NH3
  875. New Leading and Lagging Indicators of Process Safety Performance
  876. When is Flame Retardant Clothing (FRC) Really required?
  877. PSM Operating Procedures Survey Conducted
  878. Is OSHA Targeting Ammonia Refrigeration & Chlorine water treatment processes in their new PSM NEP?
  879. States with RMP accidents causing at least one off-site Death
  880. EPA's General Duty Clause for RMP
  881. More on EPA's General Duty Clause
  882. Top 10 RMP Chemicals by On-Site Quantities
  883. Refinery Heat Exchanger Failure Fatality
  884. Concurrent Operating Procedures…Emergency Shutdown and Start-Up after ESD
  885. Some GREAT PHA Observations from one of the best in the business
  886. Some GREAT Process Safety Observations from one of the best in the business
  887. How do you define a PSM/RMP contractor and what does your evaluation process look like?
  888. NH3 Releases occurring in NY state from 1993-98
  889. Difference in Emergency SOPs and Emergency Response Plan
  890. Unloading Hoses and PSM/RMP
  891. IMPORTANT NOTICE regarding NH3 and LPG hoses
  892. Hot Work Requirements and Combustible Dusts
  893. Hot Work Preparation and OSHA Requirements
  894. Hot Work Safety and learning from others costly errors
  895. Better be thinking MOC before you do RBI
  896. Mechanical integrity management of bulk storage tanks
  897. Trick Question or legit question for PSM Compliance? Contractor Evaluations and PRCS Rescue Evaluations
  898. What are "Temporary Operations" in regards to PSM Operating Procedures 1910.119(f)(1)(i)(C)
  899. The difference between a MOC and PSSR
  900. Staffing and Management of Change
  901. What is a RAGAGEP?...and what it is NOT
  902. Ventilation...Can I use it to declassify a HAZLOC?
  903. Missed Preventive Maintenance Inspections/Tests
  904. Emergency Shutdown (when does it get activated)
  905. Car Seal Program and Relief Valves
  906. How to use your PHA to write your SOPs
  907. Starting point for PSM Facility Siting when dealing with Flammables (updated with LPG on 8/12/12)
  908. Is your Diking in your PSI and MI
  909. Tips when performing PHA's and how Chemical Process Safety should be viewed
  910. Buying a used PSM/RMP facility or used equipment for PSM/RMP
  911. Report reveals fundamental management flaws lay behind Buncefield disaster
  912. UPDATE on Chemical Facility Anti-Terrorism Standards (CFATS)
  913. Pressure Testing vs. Leak Testing for Mechanical Refrigeration Processes
  914. CSB Releases Case Study on Fatal 2008 Accident at a Tire and Rubber Plant
  915. Car-Seal Programs and how they operate
  916. Flaw in NH3 Emergency Ventilation Design?
  917. Managing your Relief Valves
  918. "Lessons Learned" potentials from Japan's Nuclear Problems
  919. Liquid Penetrant Examination (NBBI)
  920. Guidance for Conducting Risk Management Program Inspections under Clean Air Act Section 112(r)
  921. LOPA and SIS/SIL
  922. Valves installed backwards?
  923. 2010 SECTION VIII — DIVISION 1 NON-MANDATORY APPENDIX M - INSTALLATION AND OPERATION
  924. Post Weld Heat Treating (PWHT) failure
  925. Management of Organizational Change (OSHA Letter to RAs)
  926. EPA Can Improve Implementation of the Risk Management Program for Airborne Chemical Releases (EPA OFFICE OF INSPECTOR GENERAL)
  927. Process Hazards Analysis Techniques (Methodologies, Resources, and Time)
  928. Rupture Disc between Pressure Vessel and Relief Valve (and after the RV)
  929. Catastrophic Failure during pneumatic pressure test
  930. Brittle Fracture (Catastrophic) Failure during HYDROTEST of Propane Bullet
  931. What does "relief system design basis" mean?
  932. Cellular Phones and Other Risks in Classified Areas
  933. The BASICS on PRESSURE VESSEL SAFETY (OSHA)
  934. OSHA Q&A on PSM Compliance (CPL02-02-045, 1994)
  935. 5,700-gallon hydrochloric acid (HCl) storage tank ruptured during filling

The U.S. Chemical Safety Board has released preliminary findings from its ongoing investigation of the toxic chemical release that occurred at a distilled spirits plant in Kansas on October 21, 2016. The CSB’s investigation into the release has identified several shortcomings in the design and labeling of loading stations, as well as adherence to chemical unloading procedures.  The chemical release occurred when sulfuric acid was inadvertently unloaded from a tanker truck into a fixed sodium hypochlorite tank at the plant. The two materials combined to produce chlorine gas that sent over 140 individuals, both workers and members of the public, to area hospitals and resulted in shelter-in-place and evacuation orders for thousands of local residents. The CSB’s investigation found that at about 7:35 am, a tanker truck arrived at the facility to deliver sulfuric acid. There, a facility operator escorted the driver to a locked loading area. The operator unlocked the gate to the fill lines and also unlocked the sulfuric acid fill line. The CSB found that the facility operator likely did not notice that the sodium hypochlorite fill line was also already unlocked before returning to his workstation. The driver connected the sulfuric acid discharge hose from the truck into the sodium hypochlorite fill line. The line used to transfer sulfuric acid looked similar to the sodium hypochlorite line, and the two lines were located in close proximity.  As a result of the incorrect connection, thousands of gallons of sulfuric acid from the tanker truck entered the facility’s sodium hypochlorite tank. The resulting mixture created a dense green cloud, which traveled northeast of the facility until the wind shifted the cloud northwest towards a more densely populated area of town. The CSB investigation concluded that emergency shutdown mechanisms were not in place or were not actuated from either a remote location at the facility or in the truck.  The CSB found a number of design deficiencies that increased the likelihood of an incorrect connection, such as the close proximity of the fill lines, and unclear and poorly placed chemical labels. In addition, the CSB found that both the facility and trucking company did not follow internal procedures for unloading operations  CLICK HERE for the CSB Press Release

As we know "human factors" are specifically called in the OSHA's PSM standard and EPA's Risk Management Plan and even more specifically they are part of our Process Hazards Analysis (PHA).  However, many do not understand what "human factors" are all about, so I thought I would share another picture I captured in my travels to help demonstrate a serious error in "human factors".  Do you see the "conflict" in this picture?  What am I suppose to do?  Do we have conflicts like this in our covered process areas or in our administrative controls like our Safe Work Practices, Operating Procedures, and/or maintenance procedures?  What would you in this situation?

The multiple-fatality explosion on October 17, 2016 explosion and subsequent fires at the german facility has been determined to be caused by a contractor cutting into an incorrect line/pipe containing flammable raffinate.  Two employees of the on-site fire department and an employee of a tanker which was anchored in the harbor died in the accident. Another employee of the on-site fire department who was severely injured in the explosion died on October 29. Seven people were seriously injured and another 22 suffered slight injuries. 

Course of events:

 
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