Tag Archives: General Duty

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

Posted on February 26, 2018 by Brian Chapin

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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What the Ammonia refrigeration industry can learn from West, TX

Posted on January 29, 2016 by Brian Chapin

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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CSB Releases Safety Video on 2009 Fatal Blast at NDK Crystal – Animation Depicts Stress Corrosion Cracking; Vessels Were Not Inspected or Tested

Posted on November 14, 2013 by Brian Chapin

Today the CSB issued a report on a 2009 vessel failure that it blamed on Stress Corrosion Cracking. There are some interesting lessons to be learned about incident investigation in this report since the mechanism that led to the vessel’s … Continue reading →

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Ammonia citations under the General Duty clause

Posted on July 17, 2012 by Brian Chapin

Most of us in the Ammonia Refrigeration industry are dealing with a PSM covered process, but there are some of us who are not required to implement PSM because we don’t have a threshold quantity. The real worry for those … Continue reading →

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No NH3 Detection – General Duty Citation in store?

Posted on January 13, 2012 by Brian Chapin

Most General Duty citations have nothing to do with Ammonia refrigeration but I’ve started to see a trend recently where processes that are not covered by PSM are being subject to Recognized and Generally Accepted Good Engineering Practices (RAGAGEP). The … Continue reading →

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