1461331960400A postdoctoral researcher was combining 70% hydrogen, 25% oxygen, and 5% carbon dioxide gases from high-pressure cylinders into a lower pressure tank when an explosion occurred that severed her right arm just above the elbow. The gas mixture was “food” for bacteria being used to produce biofuels and bioplastics. She was working for the Hawaii Natural Energy Institute under another researcher.  In a 2013 paper by the supervising researcher, it shows a similar set-up in which gases are plumbed through a mixing device directly into the bioreactor (Int. J. Hydrogen Energy 2013, DOI: 10.1016/j.ijhydene.2013.04.153). The gas gauge identified in that paper was an “intrinsically safe” model designed for use with flammable gases.  But after the postdoctoral researcher started in the lab last fall, she purchased a 49-L steel gas tank, a DIFFERENT gauge, one that was NOT rated as intrinsically safe, a pressure-relief valve, and fittings, and she put them together. She told fire department investigators, she would add the gases to the portable tank, which would then be connected to the bioreactor.  In the week before the incident, a similar set-up with a 3.8-L tank resulted in a “small internal explosion” when she pressed the OFF button on the same type gauge.  She also occasionally experienced STATIC SHOCKS when touching the 3.8-L tank, which was NOT grounded. She reported the shocks and possibly the small explosion to the  supervising researcher, who told her not to worry about it.  On the day of the incident, the 49-L tank exploded when she pressed the OFF button on the gauge. 

The University of Hawaii hired the University of California Center for Laboratory Safety to independently investigate the incident. That report is expected to be completed by the end of this month. The Hawaii Occupational Safety & Health Division is also investigating the incident.

CLICK HERE for the FULL Honolulu Fire Department Report which contains scene photos and more valuable data.

Full disclosure, I do PSM/RMP audits, but that does not change the facts that I will present in this article. Over the past couple of years I have seen first hand companies cancel or fail to schedule their 3-year PSM/RMP audits because their State EPA, Federal EPA or OSHA did a PSM/RMP inspection at their facility and they feel this “inspection” counts as a 3-year audit. They could not be further from reality and here’s why:

On March 23rd a worker at a seafood processing building/warehouse in Boston, MA was killed in a catastrophic release of anhydrous ammonia. Since then there has been much speculation as to how this tragedy occurred and whether or not the facility's refrigeration process fell under OSHA’s PSM and EPA’s RMP standards. As it appears at the time of this writing, neither OSHA’s or EPA’s process safety standard(s) applied to this refrigeration process as the process appeared to be under the 10,000 pounds threshold(s). But the state of Massachusetts has it’s own version of Process Safety standards in the way of 527 CMR 33.00: HAZARDOUS MATERIAL PROCESS OR PROCESSING and this state code does indeed cover this refrigeration process and this fatal accident.  The “purpose” of 527 CMR 33.00 was to set state requirements lower than OSHA PSM thresholds and to create local fire department permit requirements for facilities engaging in the processing of certain hazardous materials.  The code is based on a classification system and requires disclosure and evaluation regarding a facility’s hazardous material operations.  Here's more on the state's (Massachusetts) Hazardous Material Processing Code and how it would apply to this ammonia refrigeration process:

One of the means to protect an OUTSIDE atmospheric storage tank is a weak roof-to-shell seam.  As we can see in this video, a diesel tank at wharf in Apia, Samoa was equipped with such a means of fire venting.  I am assuming this on the basis of the information we can obtain from the drone footage.  We see the other two (2) diesel tanks do NOT have a normal emergency vent and the fact the the entire roof is gone on the tank that is on fire.  This means of emergency venting is permitted ONLY on OUTDOOR tanks and we can see why, but they do work.  Had the responding FD had an adequate supply of foam, this fire could have easily (relatively speaking) extinguished.  Notice how the tank integrity was maintained and the diesel was contained within the tank.

NOTE: this tank fire was caused by Hot Work on the tank while the tank was in service.  Diesel fuel will EXPLODE and in fact it's LEL is HALF of Gasoline's LEL!!!  Of course it's FP is 145F, but once we get vapor present, it takes only 0.5% to be explosive!


Drone Footage Shows Apia Fuel Storage Tanks Fire by storyfulviral

CLICK HERE to see the location of the tank roof and additional footage.

  1. Using a pressure vessel that does NOT carry the ASME Stamp in the state of CA?
  2. 1998 BLEVE Aniversary
  3. A part of process safety history ending this week (70 ton CL2 release)
  4. Proud moment for SAFTENG
  5. OSHA's GDC for Nitrogen Pressure Vessel Manifold Failure Fatality
  6. Pipe flanges, screwed connections, fittings, valves, meters, etc. and our Hazardous Locations
  7. Inside look at OSHA's desired PSM revisions
  8. Cost–Benefit Analysis of Proposed California Oil and Gas Refinery Regulations (RAND Corp)
  9. How safe is your Permit-to-Work management system? (QRA Results)
  10. Low Pressure storage tank @ brewery catastrophically fails (RD installed upside down)
  11. Crocker Park Propane Tank BLEVE (Update #4 03/14/16)
  12. EPA releases Q&A's on Proposed Changes to the RMP Rule
  13. Free PSM Workshop on April 29, 2016 (WA-OSHA, officially called Department of Labor and Industries )
  14. What is the REQUIRED FREQUENCY of my relief valve(s) maintenance
  15. Tying your Maximum Intended Inventory back to your material and energy balances
  16. A sneak peek @ EPA's Revised RMP Rule (the NPRM)
  17. OMB approves EPA's NPRM on the Risk Management Plan revisions (Modernization of the Accidental Release Prevention Regulations Under Clean Air Act)
  18. FM Global offers FREE GUIDANCE on implementing a "car seal" program
  19. The power of a vacuum (Videos w/ Railcar and Tank Truck)
  20. OSHA requesting permission to inspect "small businesses" who have PSM covered processes
  21. Did a terrorist group and anhydrous ammonia just validate DHS's CFATS?
  22. Does your PSM/RMP utilize “check valves” as a safe guard to PRVENT “reverse flow”?
  23. Defining our Safety Systems in our PSI
  24. HAZLOC's and "Fitness Bands" (Part II)
  25. HAZLOC's and "Fitness Bands" (Part I)
  26. BEST PRACTICES in Contractor Management (NSC White Paper)
  27. ASME BPV Manufacturers' Data Reports On-Line Ordering Information
  28. Catastrophic failure of non-coded pressure vessel (Fatal)
  29. Managing your HFO-1234yf BLEVE risk (Part 6)
  30. West, TX Fertilizer Plant Explosion analysis (videos/photos)
  31. OSHA PSM citations @ chemical manufacturer (Flammables & $66K)
  32. Failure of Relief System results in two (2) fatalities (WorkSafeBC)
  33. FRESH AIR intakes for a ventilation system need to be from a source of FRESH AIR!
  34. Butterfly valves and relief valve line isolation
  35. Example of IMPROPER welding on pressure vessel(s)
  36. ASME B31.5 Pressure Testing and Leak Testing Requirements for Ammonia Refrigeration Processes
  37. OSHA's Interim PSM Enforcement Policy (December 23, 2015)
  38. 2015 OSHA PSM activity by Industry Sectors
  39. Process Opening/Line Break Accident due to IMPROPER LOTO (Government of Western Australia)
  40. Risk Management Plan (RMP) Facilities by the numbers (12/2015)
  41. Worked Example of how a Category 1 Flammable Gas process can be DESIGNED so as to NOT be a PSM Covered process
  42. Is “dispersal of inventory” an accepted method to maintain inventories BELOW PSM/RMP Thresholds?
  43. Runaway: Explosion at T2 Laboratories
  44. OSHA's PSM Retail Exemption, Anhydrous Ammonia, and 2016 Omnibus Bill
  45. Anhydrous Ammonia leads RMP 5-year Accident Histories with Injuries
  46. FM Global UPDATES their Hot Work Fire Statistics involving contractors (2013)
  47. A chance to hear the reasoning/rationale behind Cal/OSHA's PROPOSED rules for "PSM @ Refineries"
  48. Excess Flow Valves and the International Fire Code (IFC)
  49. Legal UPDATE on OSHA's interpretation of a "retail facility" 
  50. EPA memorandum to establish EPA policy on the effect of the OSHA's reinterpretation of the "retail exemption"
  51. A Few Good Auditors (as adapted from the movie A Few Good Men by Joe Chandler
  52. Report of Violation Findings for Third Quarter 2015 (NBBI)
  53. Review of accidents involving ammonia (Institute For Systems Engineering And Informatics)
  54. Analysis of Liquid Ammonia Leakage Accidents based on Safety System Engineering Theory
  55. Explosion of a sulphuric acid tank (H2 Explosion - 2009 France)
  56. Analysis of Accidents in Chemical Process Industry and Lessons Learnt
  57. Start-Up Accident - Metal scaffold deck ejected out of cooling tower (PSSR FAILURE)
  58. HAZARD ALERT - FIRST LINE BREAK (WorkSafeNB)
  59. Is your HHC/EHS a “Category M Fluid” (ASME B31.3)?
  60. What is NURF in the PSM World?
  61. Pressure Vessel Failure Study OSHA PSM citations @ refinery (Document Control & $77K)
  62. Is changing the "service" of your pressure vessel a change that requires an MOC?
  63. Do your pressure vessels design meet RAGAGEP requirements for "pressure differential" between set point and operating pressure? (NB-23)
  64. CalARP looking to add a PROGRAM 4 for Refineries
  65. CalARP Regulation DRAFT PROPOSED Amendments for Petroleum Refineries Emergency Response
  66. Chemical Safety Alert: Safer Technology and AlternativesWhat an Ammonia Vessel inspection and their RVs should look like
  67. CFATs Program Statistics as of November 2, 2015
  68. CSB FY 2015 Management Challenges (OIG Report)
  69. Why Excess Flow Valves FAIL
  70. FAQs from OSHA on their REVISED PSM Retail Exemption Policy
  71. NH3 fatality filling nurse tank (Summary Nr: 200513448)
  72. Could HFO-1234yf have a short live span in our car's AC unit?
  73. Pressure Vessel Inspections 101
  74. Gasoline Storage Tank Overfill Explosion (CSB)
  75. Worked Example of Process Safety Information - “Consequences of Deviation”
  76. OSHA extends the compliance deadline for the REVISED PSM "Retail" Exemption (10/20/2015)
  77. Think you have control of your contractors? We may need to think again…
  78. Material and Energy Balance and "change to facilities that affect a covered process"
  79. ASME CODE and NBIC CHANGES 2015 EDITION
  80. What it looks like to go from a Level 2 RMP to a Level 3 RMP Refrigerant
  81. HFO-1234yf and Flame Retardant Clothing (Part 5)
  82. Comparing EPA's RMP Level 2 to Level 3 Programs
  83. What is the real reason for Maximum Intended Inventory?
  84. Difference in PSI Safe Upper/Lower Limits and SOPs Operating Limits
  85. Processing Facilities and PHMSA Jurisdiction (w/OSHA)
  86. Learnings from a catastrophic release of 24,000 pounds of methyl mercaptan
  87. FREE Chemical Reactivity Worksheet (NOAA) and 1910.119(d)(1)(vii)
  88. DHS CFATS - Anhydrous Ammonia Top-Screen extensionA REAL working example of how OSHA's 1% Rule changes everything
  89. MOCs and Technology
  90. DHS CFATS - What needs to be done when a facility is bought or sold?
  91. Deciphering HHC/EHS Concentrations for PSM/RMP Applicability
  92. Consolidating two (2) Risk Management Plans into one (1)
  93. Your RMP and Earthquakes, Floods, Tornadoes and Hurricanes
  94. EXCELLENT short video on IIAR Pipe Labeling for NH3 Refrigeration Refrigerant
  95. HFO-1234yf is a PSM HHC with “special or unique hazards” (Part 4)
  96. Examples of catastrophic failure of NH3 refrigeration vessels caused by stress corrosion cracking (FMCSA)
  97. Is the Refrigerant HFO-1234yf a BLEVE risk? (Part 3)
  98. Dutch BLEVE Study (Department of Multi-Scale Physics, Faculty of Applied Sciences Delft University of Technology
  99. Cal-OSHA PSM citations @ refinery (Flammables & $566K)
  100. EPA RMP citations for "failure to update RMP every five years and §68.15 Management
  101. Process Safety irony of the week
  102. Refrigerant HFO-1234yf is a Flammable "4" in the NFPA 704 Diamond (Part 2)
  103. Refrigerant HFO-1234yf is a PSM Highly Hazardous Chemical (Part 1)
  104. Using Purged and Pressurized Enclosures for Electrical Equipment (Hazardous Locations)
  105. OSHA's PSM Retail Exemption Interim Enforcement Policy
  106. How does OSHA’s revised PSM “retail exemption” policy impact my RMP?
  107. OSHA issue PSM Retail Exemption Interim Enforcement Policy
  108. 2014 Report of Violation Findings on Pressure Vessels and Pressure Relief Devices (NBBI)
  109. National Board's 2015 First Quarter Violation Report (NBBI)
  110. Our contractors and their “subs”
  111. Proposed Regulatory Changes to Improve Oil Refinery Safety (CalEPA)Plant Ageing Study (UK's HSE COMAH )
  112. Will our cars soon be miniature PSM/RMP covered processes due to the “mildly flammable” refrigerant they will contain?
  113. EPA Seeks Input on Modernizing the Risk Management Plan (RMP) Rule
  114. Making the case my PSM/RMP covered process complies with RAGAGEPs (Vessels)
  115. EPA RMP vs. CalARP (CA Accidental Release Program)
  116. OSHA's presentation on RAGAGEP Enforcement from 2015 ASSE
  117. How OSHA’s move to EPA’s “1% rule” for mixtures change at facilities handling OSHA PSM HHC mixtures
  118. What the heck is "partial pressure" and how do I calculate it for my PSM/RMP mixture?
  119. OSHA memo on Process Safety Management of Highly Hazardous Chemicals and Covered Concentrations of Listed Appendix A Chemicals (same as EPA's 1% Rule)
  120. OSHA memo on RAGAGEP in Process Safety Management Enforcement
  121. Another atmospheric tank over-flow incident with a flammable liquid (CSB)
  122. OSHA's presentation on RAGAGEP Enforcement from 2015 ASSE
  123. Example Contractor Work Permit
  124. EO 13650 Actions to Improve Chemical Facility Safety and Security (Working Group Update)
  125. ASSE 2015 Presentation and PSM Inspection Data (2/27/2014 to 3/30/2015)
  126. A Process Hazards Analysis is NOT an “engineering review” - Part II
  127. A Process Hazards Analysis is NOT an “engineering review”
  128. Pipe labeling by way of ASME A13.1
  129. NH3 Line Break accident
  130. FATAL failure of an anhydrous ammonia compressor
  131. Ammonia Line Rupture Kills One Worker, Injuring Two
  132. Chemical Security Program Statistics as of May 1, 2015
  133. OSHRC on PSM, Guarding, and HAZCOM from a Refinery NEP
  134. Is a bollard just a post?
  135. Excess Flow Valves... Installation, Testing and PM requirements
  136. DIR Releases Status Report on Process Safety Management Regulatory Oversight of California's Petroleum Refineries
  137. EPA is getting in the game of issuing citations for NOT doing an MOC on "staffing changes"!
  138. Shock to the System (CSB Video on Hydraulic Shock in Refrigeration)
  139. IL Pressure Vessel Inspection Frequency (DRAFT FM Procedure)
  140. Chemical Security Program Statistics as of March 2, 2015
  141. Interesting look at some RMP Data
  142. Cal ARP Regulation Amendments 2015
  143. Line Break Gone BAD due to IMPROPER LOTO and OSHRC vacates all OSHA citations (not a type-o!)
  144. Do you “certify” your 3-year PSM/RMP compliance audits?
  145. Consider the assumptions made during a PHA Facility Siting Assessment (Pipe Bridges)
  146. RMP Facilities in the United States as of December 2014 (Congressional Research Service)
  147. Region 5 RMP Presentation (one of the best)
  148. Anhydrous Ammonia at Refrigeration Facilities Under Scrutiny by U.S. EPA
  149. A look into what EPA expects in our RMP 3-year audits
  150. MOCs are much like WORD or EXCEL… they can do so much more than we use them for
  151. PSM Battery Limit Scenario w/ gas cylinders stored within the same building w/ NO passive fire barrier separation (OSHA LOI)
  152. RMP Program Level Flowchart (LA-DEQ)
  153. FM Global Data Sheet beat CSB to punch on Hydraulic Fracturing in NH3 Refrigeration Systems
  154. Chemical Security Program Statistics as of January 5, 2015
  155. CFATS Corporate Approach (DHS 1/20/15)
  156. Boiler Operator Attendance EXCEPTION Requirements now mirror a PSM/RMP style management system
  157. Anhydrous Ammonia Safety Bulletin - Five Key Lessons to Prevent Hydraulic Shock (CSB)
  158. Does a facility have an obligation to notify DHS if the facility is closing?
  159. Dual Stamped pressure vessels
  160. Safety systems and their functions in our SOPs
  161. PSM/RMP Refresher Training Frequency is not a 1,094 day vacation from training!
  162. Another MI Lesson to be learned - Tank Integrity
  163. UK’s HSE issues guidance on RBI Maintenance Programs
  164. HHC/EHS UNLOADING reliance on Excess Flow Valves and another lesson on pipe erosion-corrosion
  165. Congress Passes Legislation to Reinforce Protection and Security of Chemical Facilities
  166. ANSI Z49.1:2012 Available for FREE Download (pdf)
  167. Marsh 1974-2013, Large property damage losses in the Hydrocarbon Industry - 23rd Edition
  168. Another MI learning opportunity with regard to corrosion in piping
  169. Interesting PSM/RMP nuggets from the 12/11/14 Senate hearing on EO - IMPROVING CHEMICAL FACILITY SAFETY AND SECURITY
  170. The fundamentals behind “line breaking”
  171. Christmas eve refinery explosion caused by frozen pipe (Technical Safety Authority of Saskatchewan Executive Report)
  172. Joint Full Committee Hearing - Oversight of the Implications of the President’s Executive Order on Improving Chemical Facility and Security Committee
  173. Chemical Security Program Statistics as of November 1, 2014
  174. UK's HSE Human Factors Briefing Notes
  175. Testing for water in your Ammonia Refrigeration Process
  176. Relief Devices and Condensers in NJ
  177. Interesting RV replacement schedule for PV’s holding NH3 in WI
  178. Bench Testing your Relief Valves and IIAR Edit CAL OSHA's PROPOSED PSM Standard for Refineries
  179. OSHA’s revised Injury and Illness Reporting may call for an MOC at PSM/RMP facilities
  180. Hazardous Locations (HAZLOCs) and Medical Devices
  181. Catastrophic failure of Ammonia Cryogenic Storage Tank w/ Ammonia Fire (7 deaths and 57 injured)
  182. How far would you go with the “co-Location” coverage to determine PSM/RMP coverage?
  183. If this looks familiar... well, you may need some help (Cartoon)
  184. Some interesting changes coming to CalARP
  185. What to Expect from a CFATS Authorization Inspection (DHS)
  186. DHS issues ANPRM for CFATS
  187. ANSI K61.1-1999 Updated and is now CGA 2.1-2014
  188. Process Safety and calibrated direct-reading instrument
  189. 10 years of NH3 and CL2 release data (2004-2014)
  190. OSHRC decision on PSM Contractor Training and Work Permits
  191. Purposely Setting a Valve Higher than Nameplate Stamping: Acceptable or Not? (NBBI)
  192. 08/08/14 UPDATE - Anhydrous Ammonia (NH3) Fatality at a NE Co-Op was an UNLOADING ACCIDENT
  193. CA Ice Rink forced to shutdown by local FD because of failure to comply with CalARP
  194. EPA's Risk Management Program (RMP) Request for Information (RFI)
  195. UPDATE on NH3 Fatality... Coroner's Jury Rules on Anhydrous Ammonia Incident
  196. Flammable Liquids process, PSM, MOC and simultaneous flows
  197. API Releases three (3) New Standards
  198. Your RMP "Emergency Contact"
  199. U.S. EPA Risk Management Plan (RMP) Webinars and Training - RMP*eSubmit Webinars
  200. Boiler and Pressure Vessel Report of Violation Findings for First Quarter 2014
  201. Hazards of Hot Work on Vessels/Containers
  202. Just some random thoughts about "Detectors in my header"
  203. Catastrophic Failure of a Liquid N2 Storage Tank - BLOCKED IN scenario (Japan, 8/28/1992)
  204. UK's HSE guidance on failure modes in Refrigeration Processes
  205. SOP annual certifications and 40 CFR Part 68.200 Recordkeeping (RMP)
  206. TX Fertilizer Plant Explosion analysis (videos/photos)
  207. Is your Engine Room capable of withstanding your WCS?
  208. FREE EPA RMP Training for Ammonia in Ag
  209. Does changing a Relief Valve on a “Header/Manifold” require a line break permit at your facility?
  210. RMP*eSUBMIT Users’ Manual 2014 Update
  211. High Pressure Shutdown Switch Fails - Catastrophic Equipment Failure
  212. Using MARPLOT to obtain your 2010 Census data for your 2014 RMP UPDATE
  213. PRESSURE VESSEL GUIDELINES (OSHA 2014)
  214. Flame Resistance Clothing (FRC) program needs
  215. Another "Unload to Wrong Tank" Incident (Nitric Acid into Caustic)
  216. CCPS Interview with OSHA’s Jordan Barab (Video)
  217. PSM versus TCPA (New Jersey Work Environment Council)
  218. What is your EPA Risk Management Plan “Hazard Index”?
  219. Yep, its JUST Anhydrous Ammonia "in Refrigeration" (Part II)
  220. Excellent Advice from a Relief Valve Manufacturer regarding how to go about establishing Safe Upper Limits
  221. OSHA’s Request for Information (RFI) regarding their PSM Standard has CLOSED, but here are the comments
  222. 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
  223. Plant oil filter failure on compressor causes ammonia leak
  224. Impact of oxygen-enriched atmospheres on fire behavior (USFA)
  225. “Our Initial Start-Up Procedure(s) are the same as our Normal Start-up Procedures”... Guess again!
  226. CFATs newest FAQ Questions (Ammonium Nitrate)
  227. OSHA asking for permission to inspect PSM facilities with fewer than 10 employees
  228. Are my Railcars on site covered under RMP? (Sulphur Trioxide and Flammables/ $21,788 w/ $200,000 SEP)
  229. “Have PPE/Respirator Available”…
  230. A look at what RMP Facilities can expect from EPA in 2014
  231. OSWER Risk Management Program Evaluation Scoping Project (EPA’s path forward in determining who should get an RMP inspection)
  232. CAA 112(r) Inspections - What to expect & suggestions from the inspectors
  233. EPA’s Office of Inspector General says Improvements Needed in EPA Training and Oversight for RMP Inspections
  234. 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
  235. PSM Inspection Data UPDATE
  236. Massachusetts 527 CMR 33.00: Hazardous Materials Process or Processing (UPDATED)
  237. The 2013 National Board Incident Report (Based on 2002-2008 OSHA Data)
  238. Relief Valve (RV) Header vs. Directly to Atmosphere Edit Another example of "Temporary Operations" in Process Safety Edit
  239. Final Refinery Safety Report Calls for Greater Collaboration and Oversight to Protect the Public and Employees (CAL-OSHA)
  240. Another PSM Learning opportunity (Line Break, Safe Work Permit, LOTO, PPE, Pipe Labeling)
  241. Updating your RMP OCA Populations
  242. RISK MANAGEMENT PLAN CO-LOCATION GUIDANCE OF NON-INTERCONNECTED REGULATED SUBSTANCE VESSELS (OH EPA)
  243. Food Processing Company Settles Violations of Chemical Release Reporting Requirements (NH3 Refrigeration)
  244. Process Safety Operating Procedures and a Certified PPE Hazard Assessment
  245. Is your facility REALLY prepared for an emergency? (ERT and PSM SOPs)
  246. Vibration-induced fatigue on process pipework
  247. Are we "dumbing" down RAGAGEPs to make OSHA's job harder?
  248. API provides OPEN/FREE access to many of their codes/practices
  249. How rigorous is your contractor safety evaluation(s)?
  250. Discharging Pressure Vessel RVs back into process
  251. INTERIM CHEMICAL ACCIDENT PREVENTION ADVISORY - Design of LPG Installations at Natural Gas Processing Plants
  252. 2014 Public Listening Session Schedule and Registration Information EO 13650 Improving Chemical Facility Safety and Security
  253. EPA Region X RMP Training
  254. Does PSM/RMP standards need a Ultimate Work Authority and Stop Work Authority concepts?
  255. UPDATE - State of MA Hazardous Material Process or Processing: 527 CMR 33
  256. HAZCOM labeling changes and your PSM/RMP programs
  257. De-Rating or Re-Rating a Pressure Vessel
  258. 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
  259. Acting Responsibly? Federal Contractors Frequently Put Workers’ Lives and Livelihoods at Risk
  260. ASME's Single Certification Mark (new nameplate)
  261. Training requirements for mechanics repairing and/or testing pressure relief devices
  262. The 12 things OSHA wants to change about it PSM Standard and its enforcement
  263. Hydrofluoric Acid (HF) Fatality (TNOSHA)
  264. CSB follow-up letter to DOT regarding emergency shutdown systems for chlorine railcars
  265. EPA explains the difference between a PHA and a "Hazard Review"
  266. PHMSA answers the question... Who regulates the unloading of ammonia to a process
  267. 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)
  268. National Board Report of Violation Findings for Second Quarter 2013
  269. Another example of Catastrophic Pressure Vessel failure
  270. Changes to ANSI K61.1 (Storage and Handling of Anhydrous Ammonia)
  271. Key Process Safety Performance Indicators (UK's HSE)
  272. New Edition of Pamphlet 6, Piping Systems for Dry Chlorine, now AVAILABLE
  273. What could your NH3 38,000 pound WCS look like?
  274. PHA's and "previous incidents"
  275. Pressure Vessel Accident Rates
  276. CATASTROPHIC FAILURE of ASME Pressure Vessel (Video and CSB Investigation)
  277. OSHA is considering revising its Process Safety Management (PSM) standard
  278. First (1st) Public Review of Standard BSR/IIAR 4-201x, Installation of Closed-Circuit Ammonia Mechanical Refrigeration Systems Edit "Temporary Operations" in Ammonia Refrigeration
  279. RMP WCS and "An enclosed space in direct contact with outside air" (UPDATED 11/7/13 w/ EPA Response)
  280. Inside an EPA RMP Inspection at a Refinery
  281. BSEE Releases Panel Investigation Report into Fire and Explosion on Gulf of Mexico Platform (FATAL HOTWORK ACCIDENT)
  282. What is it? Hint: Think piping RAGAGEP
  283. Comparison of Tier II, TRI, and 112(r) Requirements
  284. Which agency (feds, state, county) enforces RMP at your facility?
  285. NBIC Pressure Relief Device (PRD) Inspection Guide
  286. Principles for proof testing of safety instrumented systems in the chemical industry (UK's HSE)
  287. RMP and Population Estimates from 2010 Census Data
  288. Challenging PHA assumptions during revalidation
  289. NH3 Refrigeration Auto Purger Design Change
  290. 3" NH3 Pipe Failure (video)
  291. Control Room Management and Human Factors
  292. PHAs and the consequences of engineering and administrative controls failing
  293. Chemical Advisory: Safe Storage, Handling, and Management of Ammonium Nitrate
  294. What is a "Tell-Tale" gauge and why is it significant in process safety
  295. Pipe RAGAGEPs and Hydrostatic relief
  296. Is the 1-U form for my pressure vessel really not a PSM requirement?
  297. OSHRC frowns on OSHA's use of "Internal Reports/Documents" to issue PSM citations
  298. What do I have to do for material and energy balances?
  299. Run to failure... Can it be done while achieving process safety?
  300. The National Board of Boiler and Pressure Vessel Inspectors Report of Violation Findings for First Quarter 2013
  301. Looking for some technical data for one of your pressure vessels?
  302. CFATs Program Statistics as of August 1, 2013
  303. 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?
  304. "It's just Ammonia" - yep it sure is!
  305. Executive Order - Improving Chemical Facility Safety and Security
  306. Passivation... PSM/RMP activity that belongs in the "initial start-up" SOP?
  307. Making the case my PSM/RMP covered process complies with RAGAGEPs (Piping)
  308. Emergency Response Program (ERP) requirements differ for PSM and RMP
  309. Control the amount of scaffolding permitted in a process area?
  310. The RAND Corporation memo for the CA-OSHA Process Safety Review
  311. Draft Report of the Interagency Working Group on Refinery Safety - Improving Public and Worker Safety at Oil Refineries
  312. PHMSA Safety Advisory - Heating Railcars
  313. EPA Region 10 Top 5 RMP violations
  314. Seven Keys to Surviving a Chem NEP Audit (John Newquist)
  315. Hansen RV's - URGENT PRODUCT SAFETY NOTICE IMMEDIATE ACTION REQUIRED
  316. OSHA reaches settlement agreement with Food Company to protect workers from NH3
  317. Answering the question... Can a Relief Valve be installed horizontally?
  318. RAGAGEPs and "the numbers"
  319. DHS CFATS Update as of June 6, 2013
  320. Human and organizational errors are the major cause of equipment failures in in the process industries
  321. Ammonia Incidents in NY State
  322. Ammonia Refrigeration FATALITY - Compressor Pump Out Valve
  323. Runaway reaction fatality explosion (TNOSHA)
  324. Line Break Fatality @ Refinery (TNOSHA)
  325. Ammonia Refrigeration FATALITY - Chiller Valve
  326. Boiler & Pressure Vessel accidents by year (from NBIC)
  327. What ISA-84 can do for process safety
  328. Considering failure of engineering controls in a PHA
  329. National Board Inspection Code vs. API 510
  330. Process Safety and Hotwork requirements
  331. Techniques for assigning a Target Safety Integrity Level (SIL)
  332. Understanding ISA-84
  333. EPA RMP Q&A on latitude and longitude coordinates (April 2011)
  334. FREE CCPS Reactivity Management Tool (RMT)
  335. June 2012 CCPS Process Beacon - Nitrogen – Hazard and Safeguard!
  336. Ammonia Explosion News Accounts
  337. EPA announces summary of enforcement actions for Winter 2012
  338. Does your PSM/RMP included power systems?
  339. DHS completes the 1000th Compliance Assistance Visit (CAV)
  340. FREE COPY of Z49.1:2012 Safety in Welding, Cutting, and Allied Processes
  341. Anhydrous Ammonia Tank Catastrophic Failure
  342. Relief Valve Maintenance & Testing
  343. Relief Valve sizing and combustible/flammable storage
  344. Has PSM driven us to dilute some “engineering standards”?
  345. Pressure Vessels, MDMT, and Auto-Refrigeration (NBBI)
  346. Implementation of New ASME Stamp for Pressure Relief Devices
  347. Bypassing of storage tank safety features
  348. Compliant with RAGAGEP?
  349. May 2012 CCPS Process Beacon - Mechanical Integrity of Tubing
  350. Are we overdoing procedures?
  351. UK's HSE REVIEW OF CHLORINE INCIDENTS 1992 - 1998
  352. MAJOR CHEMICAL DISASTERS IN INDIA
  353. Ammonia Incidents in Oregon from 1993-2007
  354. Workplace Health and Safety Queensland - Ammonia National Audit Program results
  355. UK's HSE REVIEW OF AMMONIA INCIDENTS 1992 - 1998
  356. 2012 April CCPS Process Beacon - Unloading to the wrong tank
  357. Using the common practice of “Draining Oil Pots” on refrigeration systems to examine the differences between “controlled” and “uncontrolled” releases of ammonia
  358. An interesting "Facility Change" that fell through the cracks
  359. The finer points of OSHA’s and EPA’s Management of Change requirements
  360. EPA cancels their July 2012 Public Access to RMPs
  361. Taking credit for a building in a WCS under RMP
  362. Stairs vs. Ladders and Emergency Egress
  363. March 2012 Update on OSHA’s Refinery & Chemical National Emphasis Programs
  364. Does your facility “Car Seal” or “Lock Open” Valves? Do NOT use your LOTO Locks!
  365. A close look at Incident Investigation techniques A MUST READ for ALL Safety Pro's
  366. Ammonia HAZARD ALERT issued by NC-OSHA in response to a fatal accident involving NH3
  367. Annual SOP Certifications for PSM/RMP
  368. VPP Application Supplement for the Sites Subject to the Process Safety Management (PSM) Standard
  369. Temporary MOC’s and Temporary Electrical Power
  370. Ammonia and HAZLOC's (join the debate)
  371. DHS Jack Rabbit CL2 and NH3 Release Testing presentation video (NO video of releases)
  372. Why would my NH3 ventilation discharge need to be a Hazardous Location? Unpublished
  373. Mechanical Ventilation - General Rules to live by
  374. The IMPORTANCE of Hydrostatic relief valves in Ammonia Systems
  375. RMP and Transportation Containers
  376. RMP Program Level Determination Flowchart
  377. Summary of the RMP Chemical Exemptions
  378. 2012 March CCPS Process Beacon - Double Block & Bleed Explanation
  379. Difference between OSHA’s PSM and EPA’s RMP requirements
  380. Comparison of RMP and PSM Chemicals and Thresholds
  381. State of Massachusetts Hazardous Materials Processing regulation (527 CMR 33)
  382. Challenging the NH3 Refrigeration & Electrical Classification (UPDATED 3/3/12)
  383. Is the act of loading/unloading a PSM/RMP chemical exempt from OSHA/EPA enforcement?
  384. Changing your RMP Emergency Contact
  385. Can a PHA done for OSHA's PSM be used for EPA's RMP Compliance?
  386. A reverse look at Facility Siting and Change Management
  387. How many threads of a bolt must be showing outside a nut to meet RAGAGEP?
  388. Hotwork - Learning from Losses
  389. Change(s) that REQUIRE a PHA revalidation AND RMP Update
  390. Interesting RMP Statistics - Where does your process rank?
  391. PSM Scenario Challenge - Response
  392. Hotwork Safety
  393. The advantage of utilizing a Contractor Work Permit
  394. Ammonia Gas Explosion
  395. Use of High Visibility Vest in Safety Programs
  396. Refinery NEP UPDATE (12/5/07)
  397. NFPA 30 offers some GREAT facility siting for NEW process vessels
  398. Process Hazards Analysis and “Safeguards”
  399. “Operator Rounds” in a PSM/RMP Covered Process
  400. NH3 Unloading Incident (30 Tons Release)
  401. AMMONIA SPILLS IN WISCONSIN 1993-2009
  402. The power of a vacuum (photo)
  403. Establishing your safe upper and lower limits for FLOWS
  404. Establishing Safe Upper and Lower Limits
  405. Key provisions of the PSM Preamble
  406. Tracking Corrective Actions to closure
  407. PSM, Flammable Liquids, & Secondary Containment
  408. 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
  409. OSHA Launches their PSM Covered Chemical Facilities NEP
  410. The Borden's Ammonia Explosion December 11, 1983
  411. Flammable Liquids Tank Integrity Learnings
  412. Features of successful Safety Management System (SMS)
  413. Importance of MAINTAINING your Explosion Proof Equipment (Video)
  414. PHA and Loss of Power
  415. OSHA's Pressure Vessel "Cheat Sheet"
  416. The Jack Rabbit Test Program Trial Summary - NH3 and CL2 Release Studies
  417. PSM Battery Limits - it may not be as simple as "Interconnected"
  418. More OSHA PSM Citations on a NH3 Refrigeration Process (includes NO MOC on personnel changes!)
  419. Explosion of MDEA Storage Tank
  420. How strong does my explosion have to be to do damage?
  421. Another valve that needs to be Car-Sealed OPEN
  422. Vulnerability of oil contaminated fire retardant coveralls
  423. Contractors and chemical process safety?
  424. Electrical Classification for Hazardous Locations
  425. How secure are your safety systems?
  426. PSM Coverage and the Meer decision Unpublished
  427. Management of Change (MOC) and Procedures
  428. Is EPA setting a standard for PSM/RMP Staffing Levels?
  429. Anhydrous Ammonia Stress Corrosion Cracking (SCC) Incident sends 5 to hospital
  430. Animation of January 23, 2010 Phosgene Accident
  431. CFATS Personnel Surety Privacy Impact Assessment is now available
  432. Truck Drivers being your DOT HAZMAT Attendant and potential safety and health concerns
  433. What does EPA's RMP "General Duty Clause" actually require?
  434. Buyer BEWARE regarding offsite Operator and Maintenance training courses
  435. Process Safety and Security Guards
  436. HOTWORK Tank Explosion (Video)
  437. PSM Chemical Plant NEP UPDATE March 2011
  438. Replacement in Kind... is it really?
  439. PSM/RMP "co-location" or "proximity" when determining PSM/RMP Applicability
  440. Worst Case Release Scenario and Severe Weather
  441. EPA's RMP and Program 3 NAICS #'s
  442. RMP*eSubmit Webinar Presentation
  443. THE REAL COST of an accident!
  444. A perfect storm in the making...have we learned our lesson?
  445. RMP eSubmit Webinar Questions and Answers
  446. RMP Worst Case Scenario considerations
  447. Another Example of Torque Requirements - GASKETS
  448. Torque Examples - Mechanical-Joint Assembly
  449. Torque Requirements and Process Safety Management
  450. Fire Watches and their Fire Extinguishers
  451. PSM and Electronic Management Systems and Emergency Power Systems
  452. Is Your Welding Hot Work Policy in Compliance (VIDEO - 5 minutes)
  453. Dangers of Hot Work - VIDEO (14 Min)
  454. Maintain Process Safety During the Recession (Video)
  455. Is your Fire Extinguisher Contractor covered under PSM?
  456. Ammonia HAZARD ALERT issued by NC-OSHA in response to a fatal accident involving NH3
  457. New Leading and Lagging Indicators of Process Safety Performance
  458. When is Flame Retardant Clothing (FRC) Really required?
  459. PSM Operating Procedures Survey Conducted
  460. Is OSHA Targeting Ammonia Refrigeration & Chlorine water treatment processes in their new PSM NEP?
  461. States with RMP accidents causing at least one off-site Death
  462. EPA's General Duty Clause for RMP
  463. More on EPA's General Duty Clause
  464. Top 10 RMP Chemicals by On-Site Quantities
  465. Refinery Heat Exchanger Failure Fatality
  466. Concurrent Operating Procedures…Emergency Shutdown and Start-Up after ESD
  467. Some GREAT PHA Observations from one of the best in the business
  468. Some GREAT Process Safety Observations from one of the best in the business
  469. How do you define a PSM/RMP contractor and what does your evaluation process look like?
  470. NH3 Releases occurring in NY state from 1993-98
  471. Difference in Emergency SOPs and Emergency Response Plan
  472. Unloading Hoses and PSM/RMP
  473. IMPORTANT NOTICE regarding NH3 and LPG hoses
  474. Hot Work Requirements and Combustible Dusts
  475. Hot Work Preparation and OSHA Requirements
  476. Hot Work Safety and learning from others costly errors
  477. Better be thinking MOC before you do RBI
  478. Mechanical integrity management of bulk storage tanks
  479. Trick Question or legit question for PSM Compliance? Contractor Evaluations and PRCS Rescue Evaluations
  480. What are "Temporary Operations" in regards to PSM Operating Procedures 1910.119(f)(1)(i)(C)
  481. The difference between a MOC and PSSR
  482. Staffing and Management of Change
  483. What is a RAGAGEP?...and what it is NOT
  484. Ventilation...Can I use it to declassify a HAZLOC?
  485. Missed Preventive Maintenance Inspections/Tests
  486. Emergency Shutdown (when does it get activated)
  487. Car Seal Program and Relief Valves
  488. How to use your PHA to write your SOPs
  489. Starting point for PSM Facility Siting when dealing with Flammables (updated with LPG on 8/12/12)
  490. Is your Diking in your PSI and MI
  491. Tips when performing PHA's and how Chemical Process Safety should be viewed
  492. Buying a used PSM/RMP facility or used equipment for PSM/RMP
  493. Report reveals fundamental management flaws lay behind Buncefield disaster
  494. UPDATE on Chemical Facility Anti-Terrorism Standards (CFATS)
  495. CSB Releases Case Study on Fatal 2008 Accident at a Tire and Rubber Plant
  496. Car-Seal Programs and how they operate
  497. Flaw in NH3 Emergency Ventilation Design?
  498. Managing your Relief Valves
  499. "Lessons Learned" potentials from Japan's Nuclear Problems
  500. Liquid Penetrant Examination (NBBI)
  501. Guidance for Conducting Risk Management Program Inspections under Clean Air Act Section 112(r)
  502. LOPA and SIS/SIL
  503. Valves installed backwards?
  504. 2010 SECTION VIII — DIVISION 1 NON-MANDATORY APPENDIX M - INSTALLATION AND OPERATION
  505. Post Weld Heat Treating (PWHT) failure
  506. Management of Organizational Change (OSHA Letter to RAs)
  507. EPA Can Improve Implementation of the Risk Management Program for Airborne Chemical Releases (EPA OFFICE OF INSPECTOR GENERAL)
  508. Process Hazards Analysis Techniques (Methodologies, Resources, and Time)
  509. Rupture Disc between Pressure Vessel and Relief Valve (and after the RV)
  510. Catastrophic Failure during pneumatic pressure test
  511. Brittle Fracture (Catastrophic) Failure during HYDROTEST of Propane Bullet
  512. What does "relief system design basis" mean?
  513. Cellular Phones and Other Risks in Classified Areas
  514. The BASICS on PRESSURE VESSEL SAFETY (OSHA)
  515. 5,700-gallon hydrochloric acid (HCl) storage tank ruptured during filling
  516. What differentiates a GREAT PSM/RMP audit from a "so-so" audit?
  517. What is LUP & PADHI and what does it have to do with West Fertilizer?
  518. How many Program 2 RMPs like West Fertilizer are out here?
  519. West, TX Fertilizer... a lesson in "process safety" and the "retail facility" exemption?
  520. Animation of Fire at Chevron's Richmond Refinery, August 6, 2012
  521. How could the TX fertilizer plant be a Program 2 RMP?
  522. Hydrogen Fluoride Study, Report to Congress Section 112(n)(6) Clean Air Act As Amended
  523. Nonsparking Tools (USFA)
  524. Emergency Shutdown Systems and Hydrostatic Relief Valves
  525. OSHA's "hydrocarbon fuel exemption” in PSM
  526. Facility Siting 101 - Vehicle Barriers around critical equipment (NH3 Tank Damage from Semi - Photos/Layout/RMP)
  527. What are the requirements when a component in my covered process was built to an OLD "out of circulation" RAGAGEP?
  528. 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
  529. Splitting the hairs of Process Safety (Battery Limits and Changes)
  530. Potential Issues When Wearing Non-Fire Resistant Base Layers with Outerwear Fire-Resistant Garments
  531. Guidance on Handling Cases Developed Pursuant to the FRC Enforcement Policy Memorandum
  532. Transport Company indicted in SC woman's ammonia death (Unloading NH3)
  533. PSM/RMP Trick Question (Poll)
  534. A "Manufacturer's Recommended Practice" is a RAGAGEP
  535. HAZLOCs and Ventilation and Classification
  536. A flaw with referencing info in PSM/RMP Operating Procedures
  537. Understanding the requirements of Standard Operating Procedures (SOP)
  538. OUTSTANDING Process Safety Information Worksheet
  539. Evaluating your Mechanical Integrity Program effectiveness Edit Inside look at EPA's Ammonia Alarm Expectations Edit Pressure Vessel Update (NB-132, Revision 8)
  540. OSHA's "Process Opening" Hazard Information Bulletin
  541. Unloading HAZMATs and PSM/RMP
  542. Catastrophic failure of RRCar while being steamed (Excess temp leads to exotherm runaway)
  543. Cargo Hose Rupture and Release of Anhydrous Ammonia During Offloading of a Cargo Tank Motor Vehicle at a Plant (7/15/09)
  544. Do NOT rely on Excess Flow Valves (EFV)
  545. Can I count the activation of my safety system as an actual test of the system?
  546. UPDATE: CCTV video of the Mexico Refinery Explosion on 9/19/12
  547. Sulphur sticks and ammonia leaks... are you in compliance when using these leak detection devices?
  548. Hotwork Safety (UPDATED w/ NEW Hotwork data 12/04/12)
  549. ASME UG-140... Overpressure protection by System Design
  550. What does ASME Section VIII say about "torquing values"?
  551. Can a spring-loaded Pressure Safety Valve be installed horizontially?
  552. OSHA issues PSM citations after run-away reaction results in the hospitalization of 40 workers
  553. OSHA issues PSM, HAZCOM, Asbestos, BBP, Fire Extinguishers, Walking/Working, Ladders, Guarding, Electrical, GDC, Hotwork,
  554. Hydrostatic Relief Valves and Propane Systems
  555. ASME "Lethal Service"
  556. Third Public Review of Standard BSR/IIAR 7-201x, Developing Operating Procedures for Closed-Circuit Ammonia Mechanical Refrigerating Systems
  557. Sixth Public Review of Standard BSR/IIAR 5-201x, Start-up and Commissioning of Closed-Circuit Ammonia Mechanical Refrigerating Systems
  558. Internal Combustion Engines as Ignition Sources
  559. Evaluation of Health Effects of a Chlorine Gas Release in a Poultry Processing Plant - Arkansas
  560. RMP reporting requirements, when to update, and how to submit using the new web-based system
  561. RMP's “Stationary Source” and "Incident to Transportation" exemption challenged
  562. EPA to audit the CSB????
  563. PSM Information Collection Requirements
  564. The infamous "Process Safety Contractor Safety Study" by the John Gray Institute
  565. Phillips 66 Explosion & Fire - Pasadena, TX 1989
  566. Non-Routine process opening (e.g. "Line Break")
  567. EPA Region X's RMP "Management Plan" Example
  568. A OSHRC review of PSM Citations following a 32,000 pound release (NH3 Refrigeration)
  569. Preliminary fire testing of composite offshore pedestrian gratings
  570. Perfect example of using the "Elimination/Substitution" in the hierarchy of controls as well as IST
  571. Keep'n it real during the Process Hazards Analysis Unpublished
  572. Some hazards deserve all four levels of controls! Unpublished
  573. One of the worst refrigeration accidents rarely mentioned! (2007)
  574. What is it? (Hint: Common PSM Safe Guard)
  575. National Board RV Testing Data
  576. RMP Facilities in the United States as of December 2009
  577. Re-Submitting your RMP
  578. Putting Seward, IL 38,000 NH3 release into some perspective
  579. Can Stress Corrosion Cracking (SCC) occur in Ammonia Piping?
  580. Flixborough... the beginning of the PSM movement
  581. VIDEO UPDATE on Fatal HF Release - 5 Dead 18 Injured
  582. Ohio Fire Code Requirements for Mechanical Refrigeration facilities using Ammonia
  583. OSHA Enforcement Memo - Use of Flexible Hoses in Toxic Gas Service (10/2/2012)
  584. Ohio's PSM/RMP General Duty Clause
  585. Process Safety and Ohio State Fire & HAZMAT Codes
  586. Applications and Limitations of Excess Flow Valves
  587. Ammonia Releases in North Carolina (1993-1997 Data)
  588. Loss of Containment (LOC) Data
  589. Liquefied Gas Conversion Chart
  590. When we claim alarms as "safe guards" in our PHA
  591. TOSHA cites Refinery $63,000 for Fatal Flash Fire (PSM, LOTO, PPE)
  592. EPA Region 10 RMP Newsletter- great resource!
  593. Ammonia Fatality @ Winery
  594. Amuay UCVE Event Aug 25, 2012
  595. Process Safety and "Human Factors" (w/ video)
  596. CCTV Video & photos from Chevron's Richmond, CA refinery fire
  597. OSHA issues PSM citations to a TX Refinery
  598. How does OSHA and EPA define "retail establishment" in regards to their "exemptions" from PSM/RMP
  599. OSHA issues PSM, Explosives, PPE, Machine Guarding, LOTO, Electrical, and Flammable Liquid citations after explosion at a fireworks plant
  600. Stress Corrosion Cracking of Steel in Liquefied Ammonia Service - A Recapitulation
  601. Corrosion Rates and Remaining Life/Fitness for Service
  602. Comparison of Piping Inspection Requirements in Refrigeration Industry
  603. Comparison of Pressure Vessel Inspection Requirements in Refrigeration Industry
  604. Hydrostatic Relief Devices vs. Qualified Operator, which is required?
  605. Auditing Process Safety Management Systems
  606. OSHA issues $111K in PSM Citations following explosion that severely injured worker (PSM)
  607. Flixborough Explosion (1974)
  608. (8/25/12 UPDATE from DOT) IMPORTANT NOTICE REGARDING (NH3) AND (LPG) HOSES
  609. Risks associated with Loading and Unloading HAZMAT
  610. ANSI/ASME B31 - Standards of Pressure Piping
  611. The 12 sections of the Boiler Pressure Vessel Code (BPVC)
  612. EPA fines the US Olympic Park for RMP violations related to their Anhydrous Ammonia refrigeration process
  613. OR-OSHA changes their PSM applicability to NH3 Fertilizer and the impact it will have on RMP
  614. EPA Region X RMP/EPCRA Actions April 1-June 30, 2012
  615. Process Safety and “Critical Utilities”
  616. Has EPA established a new selection criteria for RMP inspections?
  617. MI Inspection of Anhydrous Ammonia Vessel (No PWHT)
  618. Now this is Process Safety Information!!
  619. August 2012 CCPS Process Beacon - HOTWORK HAZARDS
  620. Flammable vapour cloud risks from tank overfilling incidents
  621. Excellent depiction of PSM/RMP Process Arrangements
  622. Another "Culture" Failure leads to major pipeline incident
  623. Inherently Safer Design (CSB Video)
  624. Process Safety, Staffing, and responding to alarms
  625. PSM Enforcement UPDATE from Region V
  626. A NON-PSM chemical impacting a PSM covered process
  627. WA-OSHA latest State Plan to implement PSM CHEM NEP
  628. “LOPC” of an ammonia pipe in unoccupied refrigerated spaces
  629. Culpeper, Va. settles alleged environmental violations at water treatment facility (RMP-Chlorine)
  630. Flammable Liquid and Gas PSM Citations
  631. What ISA-84 can do for process safety
  632. Considering failure of engineering controls in a PHA
  633. National Board Inspection Code vs. API 510
  634. Process Safety and Hotwork requirements
  635. Techniques for assigning a Target Safety Integrity Level (SIL)
  636. Understanding ISA-84
  637. EPA RMP Q&A on latitude and longitude coordinates (April 2011)
  638. FREE CCPS Reactivity Management Tool (RMT)
  639. June 2012 CCPS Process Beacon - Nitrogen – Hazard and Safeguard!
  640. Ammonia Explosion News Accounts
  641. EPA announces summary of enforcement actions for Winter 2012
  642. Does your PSM/RMP included power systems?
  643. DHS completes the 1000th Compliance Assistance Visit (CAV)
  644. FREE COPY of Z49.1:2012 Safety in Welding, Cutting, and Allied Processes
  645. Anhydrous Ammonia Tank Catastrophic Failure
  646. Relief Valve Maintenance & Testing
  647. Relief Valve sizing and combustible/flammable storage
  648. Has PSM driven us to dilute some “engineering standards”?
  649. Pressure Vessels, MDMT, and Auto-Refrigeration (NBBI)
  650. Implementation of New ASME Stamp for Pressure Relief Devices
  651. Bypassing of storage tank safety features
  652. Compliant with RAGAGEP?
  653. May 2012 CCPS Process Beacon - Mechanical Integrity of Tubing
  654. Are we overdoing procedures?
  655. UK's HSE REVIEW OF CHLORINE INCIDENTS 1992 - 1998
  656. MAJOR CHEMICAL DISASTERS IN INDIA
  657. Ammonia Incidents in Oregon from 1993-2007
  658. Workplace Health and Safety Queensland - Ammonia National Audit Program results
  659. UK's HSE REVIEW OF AMMONIA INCIDENTS 1992 - 1998
  660. 2012 April CCPS Process Beacon - Unloading to the wrong tank
  661. Using the common practice of “Draining Oil Pots” on refrigeration systems to examine the differences between “controlled” and “uncontrolled” releases of ammonia
  662. An interesting "Facility Change" that fell through the cracks
  663. The finer points of OSHA’s and EPA’s Management of Change requirements
  664. EPA cancels their July 2012 Public Access to RMPs
  665. Taking credit for a building in a WCS under RMP
  666. Stairs vs. Ladders and Emergency Egress
  667. March 2012 Update on OSHA’s Refinery & Chemical National Emphasis Programs
  668. Does your facility “Car Seal” or “Lock Open” Valves? Do NOT use your LOTO Locks!
  669. A close look at Incident Investigation techniques A MUST READ for ALL Safety Pro's
  670. Ammonia HAZARD ALERT issued by NC-OSHA in response to a fatal accident involving NH3
  671. Annual SOP Certifications for PSM/RMP
  672. VPP Application Supplement for the Sites Subject to the Process Safety Management (PSM) Standard
  673. Temporary MOC’s and Temporary Electrical Power
  674. Ammonia and HAZLOC's (join the debate)
  675. DHS Jack Rabbit CL2 and NH3 Release Testing presentation video (NO video of releases)
  676. Why would my NH3 ventilation discharge need to be a Hazardous Location? Unpublished
  677. Mechanical Ventilation - General Rules to live by
  678. The IMPORTANCE of Hydrostatic relief valves in Ammonia Systems
  679. RMP and Transportation Containers
  680. RMP Program Level Determination Flowchart
  681. Summary of the RMP Chemical Exemptions
  682. 2012 March CCPS Process Beacon - Double Block & Bleed Explanation
  683. Difference between OSHA’s PSM and EPA’s RMP requirements
  684. Comparison of RMP and PSM Chemicals and Thresholds
  685. State of Massachusetts Hazardous Materials Processing regulation (527 CMR 33)
  686. Challenging the NH3 Refrigeration & Electrical Classification (UPDATED 3/3/12)
  687. Is the act of loading/unloading a PSM/RMP chemical exempt from OSHA/EPA enforcement?
  688. Changing your RMP Emergency Contact
  689. Can a PHA done for OSHA's PSM be used for EPA's RMP Compliance?
  690. A reverse look at Facility Siting and Change Management
  691. How many threads of a bolt must be showing outside a nut to meet RAGAGEP?
  692. Hotwork - Learning from Losses
  693. Change(s) that REQUIRE a PHA revalidation AND RMP Update
  694. Interesting RMP Statistics - Where does your process rank?
  695. PSM Scenario Challenge - Response
  696. Hotwork Safety
  697. The advantage of utilizing a Contractor Work Permit
  698. Ammonia Gas Explosion
  699. Use of High Visibility Vest in Safety Programs
  700. Refinery NEP UPDATE (12/5/07)
  701. NFPA 30 offers some GREAT facility siting for NEW process vessels
  702. Process Hazards Analysis and “Safeguards”
  703. “Operator Rounds” in a PSM/RMP Covered Process
  704. NH3 Unloading Incident (30 Tons Release)
  705. AMMONIA SPILLS IN WISCONSIN 1993-2009
  706. The power of a vacuum (photo)
  707. Establishing your safe upper and lower limits for FLOWS
  708. Establishing Safe Upper and Lower Limits
  709. Key provisions of the PSM Preamble
  710. Tracking Corrective Actions to closure
  711. PSM, Flammable Liquids, & Secondary Containment
  712. 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
  713. OSHA Launches their PSM Covered Chemical Facilities NEP
  714. The Borden's Ammonia Explosion December 11, 1983
  715. Flammable Liquids Tank Integrity Learnings
  716. Features of successful Safety Management System (SMS)
  717. Importance of MAINTAINING your Explosion Proof Equipment (Video)
  718. PHA and Loss of Power
  719. OSHA's Pressure Vessel "Cheat Sheet"
  720. The Jack Rabbit Test Program Trial Summary - NH3 and CL2 Release Studies
  721. PSM Battery Limits - it may not be as simple as "Interconnected"
  722. More OSHA PSM Citations on a NH3 Refrigeration Process (includes NO MOC on personnel changes!)
  723. Explosion of MDEA Storage Tank
  724. How strong does my explosion have to be to do damage?
  725. Another valve that needs to be Car-Sealed OPEN
  726. Vulnerability of oil contaminated fire retardant coveralls
  727. Contractors and chemical process safety?
  728. Electrical Classification for Hazardous Locations
  729. How secure are your safety systems?
  730. PSM Coverage and the Meer decision Unpublished
  731. Management of Change (MOC) and Procedures
  732. Is EPA setting a standard for PSM/RMP Staffing Levels?
  733. Anhydrous Ammonia Stress Corrosion Cracking (SCC) Incident sends 5 to hospital
  734. Animation of January 23, 2010 Phosgene Accident
  735. CFATS Personnel Surety Privacy Impact Assessment is now available
  736. Truck Drivers being your DOT HAZMAT Attendant and potential safety and health concerns
  737. What does EPA's RMP "General Duty Clause" actually require?
  738. Buyer BEWARE regarding offsite Operator and Maintenance training courses
  739. Process Safety and Security Guards
  740. HOTWORK Tank Explosion (Video)
  741. PSM Chemical Plant NEP UPDATE March 2011
  742. Replacement in Kind... is it really?
  743. PSM/RMP "co-location" or "proximity" when determining PSM/RMP Applicability
  744. Worst Case Release Scenario and Severe Weather
  745. RMP*eSubmit Webinar Presentation
  746. THE REAL COST of an accident!
  747. A perfect storm in the making...have we learned our lesson?
  748. RMP eSubmit Webinar Questions and Answers
  749. RMP Worst Case Scenario considerations
  750. Another Example of Torque Requirements - GASKETS
  751. Torque Examples - Mechanical-Joint Assembly
  752. Torque Requirements and Process Safety Management
  753. Fire Watches and their Fire Extinguishers
  754. PSM and Electronic Management Systems and Emergency Power Systems
  755. Is Your Welding Hot Work Policy in Compliance (VIDEO - 5 minutes)
  756. Dangers of Hot Work - VIDEO (14 Min)
  757. Maintain Process Safety During the Recession (Video)
  758. Is your Fire Extinguisher Contractor covered under PSM?
  759. Ammonia HAZARD ALERT issued by NC-OSHA in response to a fatal accident involving NH3
  760. New Leading and Lagging Indicators of Process Safety Performance
  761. When is Flame Retardant Clothing (FRC) Really required?
  762. PSM Operating Procedures Survey Conducted
  763. Is OSHA Targeting Ammonia Refrigeration & Chlorine water treatment processes in their new PSM NEP?
  764. States with RMP accidents causing at least one off-site Death
  765. EPA's General Duty Clause for RMP
  766. More on EPA's General Duty Clause
  767. Top 10 RMP Chemicals by On-Site Quantities
  768. Refinery Heat Exchanger Failure Fatality
  769. Concurrent Operating Procedures…Emergency Shutdown and Start-Up after ESD
  770. Some GREAT PHA Observations from one of the best in the business
  771. Some GREAT Process Safety Observations from one of the best in the business
  772. How do you define a PSM/RMP contractor and what does your evaluation process look like?
  773. NH3 Releases occurring in NY state from 1993-98
  774. Difference in Emergency SOPs and Emergency Response Plan
  775. Unloading Hoses and PSM/RMP
  776. IMPORTANT NOTICE regarding NH3 and LPG hoses
  777. Hot Work Requirements and Combustible Dusts
  778. Hot Work Preparation and OSHA Requirements
  779. Hot Work Safety and learning from others costly errors
  780. Better be thinking MOC before you do RBI
  781. Mechanical integrity management of bulk storage tanks
  782. Trick Question or legit question for PSM Compliance? Contractor Evaluations and PRCS Rescue Evaluations
  783. What are "Temporary Operations" in regards to PSM Operating Procedures 1910.119(f)(1)(i)(C)
  784. The difference between a MOC and PSSR
  785. Staffing and Management of Change
  786. What is a RAGAGEP?...and what it is NOT
  787. Ventilation...Can I use it to declassify a HAZLOC?
  788. Missed Preventive Maintenance Inspections/Tests
  789. Emergency Shutdown (when does it get activated)
  790. Car Seal Program and Relief Valves
  791. How to use your PHA to write your SOPs
  792. Starting point for PSM Facility Siting when dealing with Flammables (updated with LPG on 8/12/12)
  793. Is your Diking in your PSI and MI
  794. Tips when performing PHA's and how Chemical Process Safety should be viewed
  795. Buying a used PSM/RMP facility or used equipment for PSM/RMP
  796. Report reveals fundamental management flaws lay behind Buncefield disaster
  797. UPDATE on Chemical Facility Anti-Terrorism Standards (CFATS)
  798. CSB Releases Case Study on Fatal 2008 Accident at a Tire and Rubber Plant
  799. Car-Seal Programs and how they operate
  800. Flaw in NH3 Emergency Ventilation Design?
  801. Managing your Relief Valves
  802. "Lessons Learned" potentials from Japan's Nuclear Problems
  803. Liquid Penetrant Examination (NBBI)
  804. Guidance for Conducting Risk Management Program Inspections under Clean Air Act Section 112(r)
  805. LOPA and SIS/SIL
  806. Valves installed backwards?
  807. 2010 SECTION VIII — DIVISION 1 NON-MANDATORY APPENDIX M - INSTALLATION AND OPERATION
  808. Post Weld Heat Treating (PWHT) failure
  809. Management of Organizational Change (OSHA Letter to RAs)
  810. EPA Can Improve Implementation of the Risk Management Program for Airborne Chemical Releases (EPA OFFICE OF INSPECTOR GENERAL)
  811. Process Hazards Analysis Techniques (Methodologies, Resources, and Time)
  812. Rupture Disc between Pressure Vessel and Relief Valve (and after the RV)
  813. Catastrophic Failure during pneumatic pressure test
  814. Brittle Fracture (Catastrophic) Failure during HYDROTEST of Propane Bullet
  815. What does "relief system design basis" mean?
  816. Cellular Phones and Other Risks in Classified Areas
  817. The BASICS on PRESSURE VESSEL SAFETY (OSHA)
  818. 5,700-gallon hydrochloric acid (HCl) storage tank ruptured during filling

Sometimes I come across some items as I do work for clients that are priceless in helping us make our case for safety and this one is a "feather in our [hard] hat".  Apparently some employers in the state of California decided that using pressure vessels built to some code other than ASME Section VIII was a means to "save money" or for some other crazy reason.  The state of CA took issue with this practice and issued a memo way back in 2006 explaining how these businesses could get an official exemption from CAL-OSHA to use a "non-coded" pressure vessel.  Their request for information to determine if such a vessel could be used safely speaks volumes to "pressure vessel safety" and provides us some excellent insight into what goes into a pressure vessel safety management program...

 
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