Category Archives: Good Engineering Practices

IIAR 6 Public Review #3

Make your opinion known BEFORE the changes go final! IIAR 6 continues its development. This document will replace IIAR Bulletin 110 (among others) and will be very important. The current review only lists changes since Public Review #2. To: IIAR Members … Continue reading

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Learning from Failure

“Failure is only opportunity to begin again. Only this time, more wisely.” –Henry Ford We often push PSM practitioners to perform Incident Investigations for fairly minor events in the hopes that the lessons learned from those minor incidents will stop … Continue reading

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General Duty vs. PSM/RMP: Is there a benefit to dropping below the 10,000lb threshold?

Several times a year I get a phone call or an email from a client that wants to lower the NH3 inventory below the federal 10,000lb threshold so they are no longer subject to the PSM/RMP rules. It’s a conversation … Continue reading

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RAGAGEP Hierarchy in Application – A worked example

RAGAGEP (Recognized and Generally Accepted Good Engineering Practices/Principles) is extremely important to our Process Safety programs as it helps define the boundaries of what is (and isn’t) acceptable in our processes and our management of them. There seems to be … Continue reading

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Why does my PSM program make me review the PHA during any equipment/facility MOC?

Nearly two years ago, I changed the Management of Change Written Plan template in my PSM programs to make a few changes: Removed the “minor change” and “major change” categories. Explicitly require a Process Hazard Analysis review during all equipment/facility … Continue reading

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2017 SOP Template Updates

The SOP reference element guideline and RESOP/ROSOP reference  templates have been updated for 2017. The changes are basically broken into two groups: Continuous Improvement and IIAR 7. Continuous Improvement: As always, there are a lot of little change suggestions that … Continue reading

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When does a Car-Seal program make sense for Industrial Ammonia Refrigeration systems?

First off: What is a Car-Seal program and what does it do?  A Car-Seal program is designed, implemented and managed to ensure that safety-critical valves within the covered process are maintained in their safety-critical position / setting during normal system … Continue reading

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Misunderstanding MOC

Recently a valve manufacturer that I respect posted a LinkedIn advertisement for one of their new relief valves. I love new technology so I was really interested in it but noticed something they posted in the graphic: “No PSM Changes … Continue reading

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What the Ammonia refrigeration industry can learn from West, TX

Last night I attended the CSB Public Meeting in Waco, TX concerning the 2013 West, TX Ammonia Nitrate explosion. The purpose of the meeting was to release their report on the incident. The explosion resulted in 15 fatalities and 260 … Continue reading

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Shock to the system

The CSB just released a video on the August 23, 2010 Alabama ammonia release. While not perfect, it is a worthwhile video to watch as it might just make you question how you should deal with the type of power-failure issues … Continue reading

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