Recent Blog Posts
Every closed-circuit ammonia refrigeration system utilizes oil for compressor lubrication. Facilities typically maintain new oil onsite in 55-gallon drums. We have observed that it is common practice for many facilities to store reserve oil inside the machinery room. ANSI/IIAR 2-2014 §6.4 addresses the storage of combustible materials inside the machinery room. This section requires that: […]
CalOSHA’s PSM regulation (Title 8 CCR §5189(d)(3)(A)(9)) uniquely requires that the “information pertaining to the equipment in the process shall include: Electrical supply and distribution systems”. None of the other California or Federal process safety regulations (FedOSHA PSM, USEPA RMP, or CalARP) contain such a requirement. As such, literature describing best practices for implementation of […]
Title 8 CCR §5189(d)(3)(A)(8) and Title 29 CFR §1910.119(d)(3)(i)(H) requires that “information pertaining to the equipment in the process shall include: Safety systems (e.g. interlocks, detection or suppression systems)”. At minimum, Safety Systems documentation must identify and summarize all Safety Systems associated with the chemical process. Once developed, this documentation will serve as a useful […]
Title 8 CCR §5189(d)(3)(A)(7) and Title 29 CFR §1910.119(d)(3)(i)(G) require that “information pertaining to the equipment in the process shall include: Material and energy balances for processes built after May 26, 1992”. The same requirement exists in the RMP and CalARP regulation except that the applicability date is June 21, 1999 (Title 40 CFR §68.65(d)(1)(vii) […]
In addition to the technical documentation that we have discussed previously (P&IDs, Ventilation System Design, Relief System Design and Design Basis, etc.), Title 8 CCR §5189(d)(3)(A)(6) and Title 29 CFR §1910.119(d)(3)(i)(F) require that a facility have documentation describing the “Design Codes and Standards Employed” readily available for each PSM chemical process. This documentation serves multiple purposes: […]