Recent Blog Posts

Testing Ammonia Hoses (Non-Refrigeration)

April 16th, 2019

Hoses are commonly used to transfer chemicals from one container to another. Anhydrous ammonia is no exception. In non-refrigeration applications, it is important that facility owners familiarize with the requirements for pressure testing hoses. In California, OSHA requires that hoses be tested annually to twice the tank working pressure, but not less than 500 psi. […]

When Does a Relief Valve’s Clock Start?

April 2nd, 2019

While it is well known that good engineering practice requires that relief valves be replaced every five years, industry literature does not clearly state when the five-year timer starts its countdown. Is it when the valve is manufactured? Taken out of the box? Installed? Exposed to ammonia? Due to the lack of clarification on this […]

Mechanical Integrity and Prior Operating Experience

March 19th, 2019

Within the Mechanical Integrity (MI) paragraph of the PSM regulation (Title 8 §5189(j)), facility owners are required to “establish and implement written procedures to maintain the ongoing integrity of process equipment”. Inevitably, compliance with the requirements of this paragraph will require a schedule to be developed which describes the frequency that inspection, testing, and maintenance […]

Eyewash and Safety Shower Fail

March 5th, 2019

Recently while walking near a school campus pool, I observed an eyewash and safety shower installed near the pool chemical storage and injection area. To my surprise, I noticed that the valve actuator was locked to the adjacent fence, preventing the unit from functioning without first unlocking the actuator. I can’t say for certain why […]

2017 RMP Amendments and ERPWriter

February 19th, 2019

Regulatory Changes While the 2017 RMP Amendments were approved on September 21, 2018, only one of the changes has taken effect. Other changes in the amendment are likely to be repealed before they ever go into effect. The change that currently affects facilities is the addition of §68.93 to the existing Federal RMP Rule (Title […]