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Those of you that visit SAFTENG often know that I love the FM Global Data Sheets!  These data sheets are NOW FREE (and have been for a couple of years).  They serve as a GREAT AID in helping facilities understand their hazards and risks associated with all kinds of industries.  In fact, although my practice is not endorsed by Global FM, I point clients to these data sheets when an employer will not purchase costly consensus standards, as often times FM Global has a "data sheet" that will address the fundamental issue the consensus standard addresses.  Case in point... this week the Chemical Safety Board published a Safety Alert: Anhydrous Ammonia Safety Bulletin - Five Key Lessons to Prevent Hydraulic Shock (CSB).  As with most CSB publications this alert is getting shared widely among the ammonia refrigeration industry and this is a GOOD THING; but did you know that FM Global's Data Sheet 12-61, Mechanical Refrigeration had already brought to light the scenario that the CSB Alert did.  Here is what FM Global's Data Sheet 12-61, Mechanical Refrigeration Case Study #6 says...

The Department of Homeland Security (DHS) continues to strengthen security at the Nation’s high-risk chemical facilities through the Chemical Facility Anti-Terrorism Standards (CFATS) program.  Chemical Security Program Statistics as of January 5, 2015:

  • More than 48,000 preliminary assessments were reviewed by DHS from facilities with chemicals of interest
  • 3,598 facilities are currently covered by CFATS
  • More than 3,000 facilities voluntarily removed, reduced, or modified their holdings of chemicals of interest
  • 1,704 visits to assist facilities with compliance
  • 2,526 Security Plans authorized
  • 1,861Authorization Inspections conducted
  • 1,446 Security Plans approved following an on-site inspection

CLICK HERE for the DHS release

Question:  How may a corporation with multiple facilities regulated under CFATS request the corporate approach and what benefits does this provide the corporation?

A question I am asked nearly each month is... do I have to have a person dedicated to operate the boiler and is this person restricted from performing any other functions while acting as the "boiler operator"? While I am not a "boiler expert", most of my clients have industrial size boilers associated with their chemical process(s) so I deal with boiler complaince, as it relates to PSM/RMP impacts on a regualr basis. All states have "Boiler Codes" and most are similar, but not exactly the same.  Using Ohio's State Boiler Code,  which was REVISED in 2014 and became effective on 1/1/2015,  there are some methods in which an employer can implement sort of a PSM program for their boiler(s) and this would get them out of the boiler(s) having continuous, manned attendance during all times of operation for certain size and type boilers.  But if the employer does NOT like the idea of Process Safety Management (PSM) being applied to their boiler(s), they will in FACT need to maintain continuous, manned attendance during all times of operation of certain size and type steam boiler(s).  In fact, in many ways this newly revised section of the code is written so tightly that it is actually MORE demanding for operating a boiler without continuous, manned attendance than OSHA's PSM standard is for chemical processes!  Here are the REQUIREMENTS in the state of Ohio, for those types and sized boilers, to operate without continuous, manned attendance...

Millard Suction PipeThe U.S. Chemical Safety Board released a safety bulletin intended to inform industries that utilize anhydrous ammonia in bulk refrigeration operations on how to avoid a hazard referred to as hydraulic shock.  The safety lessons were derived from an investigation into a 2010 anhydrous ammonia release. The accident occurred before 9:00 am on the morning of August 23, 2010. Two international ships were being loaded when the facility’s refrigeration system experienced “hydraulic shock” which is defined as a sudden, localized pressure surge in piping or equipment resulting from a rapid change in the velocity of a flowing liquid. The highest pressures often occur when vapor and liquid ammonia are present in a single line and are disturbed by a sudden change in volume.  This abnormal transient condition results in a sharp pressure rise with the potential to cause catastrophic failure of piping, valves, and other components - often prior to a hydraulic shock incident there is an audible “hammering” in refrigeration piping. The incident caused a roof-mounted 12-inch suction pipe to catastrophically fail, resulting in the release of more than 32,000 pounds of anhydrous ammonia.

 
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