CSB Issues Safety Alert Regarding Emergency Pressure Relief Systems

CSB Issues Safety Alert Regarding Emergency Pressure Relief Systems

The Chemical Safety Board (CSB) has issued a safety alert regarding emergency pressure relief systems as the agency is continuing to see them playing their part in major chemical incidents.

Who is the CSB?

The CSB is an independent federal agency who investigates the root causes of chemical incidents at industrial sites such as chemical plants, refineries, and manufacturing facilities.  They are not a regulatory agency, but their teams of investigators make recommendations to OSHA and EPA, industry groups and the facilities they investigate.

In addition to investigation reports and root cause analyses, CSB issues safety videos on both their website and YouTube that summarize the important findings from their investigations in order to help prevent similar accidents from reoccurring.

Emergency Pressure Relief System Issues

In its investigations, CSB is continuing to find issues with the safety of emergency pressure relief systems.  In several of their investigations these systems were found to be discharging toxic or flammable materials to areas which were not safe for workers or the public.

Emergency pressure relief systems are devices installed on storage tanks, silos, vessels and processing plant equipment to help relieve the excessive pressure caused by fire, process failure, equipment failure or some other change in condition. The pressure relief device is supposed to prevent the equipment it’s installed on from rupturing or exploding.

One of the most well-known accidents involving an emergency pressure relief system was the Union Carbide disaster in Bhopal, India in the 1980s.  A runaway reaction generated high pressure conditions in a storage tank and a methyl isocyanate cloud escaped from the pressure relief system, killing 3,800 people, and injuring or creating long-term illnesses for tens of thousands.

Three Key CSB Suggestions

CSB recommends that rather than discharge into the air or back into the plant, emergency relief systems should discharge to a flare or a scrubber system.

CSB offers three key lessons from its findings:

  1. Follow Existing Good Practice Guidance

Use API 521, Pressure-relieving and Depressuring Systems as a standard guidance. CSB says this document “…addresses many concerns about releasing flammable vapors directly into the atmosphere and generally requires using inherently safer alternatives for toxic release scenarios or when the potential exists for a flammable vapor cloud.”

CSB also recommends documents published by the Center for Chemical Process Safety (CCPS) called Guidelines for Pressure-relief and Effluent Handling Systems and Safe Design and Operation of Process Vents and Emission Control Systems as well as viewing American Institute of Chemical Engineers (AIChE) presentations and courses on Venting and Emergency Relief.

  1. Evaluate Whether the Atmosphere is the Appropriate Discharge Location or if There May Be Safer Alternatives

CSB typically recommends flaring is safer than atmospheric vent stacks when venting flammable vapor into the atmosphere.  Something like flammable hydrocarbons can cause a fire or a vapor cloud explosion when they are vented into the atmosphere.  CSB recognizes flaring is safer, but does allow for venting into the atmosphere in special cases, especially when that venting will not put workers or the public at risk.

  1. Ensure Hazardous Chemicals Vented Into the Atmosphere Discharge to a Safe Location

Where are the discharge points on your emergency pressure relief systems?  Are they at areas where they can harm workers within its proximity at ground level or on walkways or platforms?   Are they near building intakes?  If your company is subject to Process Safety Management (PSM) requirements, CSB says the required periodic reviews would be a good time to evaluate these issues as well as other audits or incident investigations.

Read the Report

Find CSB’s report, along with four case studies and their resulting recommendations at https://www.csb.gov/assets/1/6/csb_eprs_alert.pdf.

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ISO 14001 Checklist

ISO 14001 Checklist

What is Environmental Management System (EMS) auditing?

An Environmental Management System (EMS) audit is the process of assessing an organization’s compliance with ISO 14001:2015, the international standard for environmental management systems.

The audit assesses whether the organization has proper procedures in place to manage its environmental responsibilities, and if any corrective actions need to be taken for non-compliance.

An Environmental Management System audit can be conducted by internal or external auditors who analyze an organization’s operational procedures, documents, records and measurements against ISO 14001:2015 requirements.

The auditor will then report their findings and make recommendations on areas of improvement that need to be addressed. Achieving ISO 14001:2015 certification demonstrates that a company takes environmental responsibility seriously and is committed to reducing their environmental impact.

It also serves as a tool for continual improvement of environmental management system processes. A successful EMS audit is essential for an organization to remain compliant with ISO 14001:2015 standards and maintain their certification status.

Organizations looking to get certified under ISO 14001:2015 need to arrange for an EMS audit, in order to assess their current environmental management system and identify any areas that require attention as well as address significant environmental aspects. The auditor will also provide advice on ways to improve the organization’s EMS and suggest best practices.

A successful audit is essential for obtaining certification and achieving a high level of compliance with ISO 14001:2015 standards. To ensure a smooth audit process, organizations should have all necessary procedures, documents, records and measurements in place prior to the commencement of the audit.

Additionally, they should take the time to train their personnel on environmental policies and requirements so that they can answer any questions from the auditor.

What to expect during ISO 14001 audit?

The key stages of an EMS audit include:

– Preparation – development of the audit plan, followed by the assessment team’s familiarization with the requirements of ISO 14001:2015.

– On-site visits – review and analysis of documents, operating criteria, records and data, as well as interviews with relevant personnel.

– Reporting – summarizing of findings in a non-conformance report that identifies areas for improvement or corrective action.

– Follow up – implementing environmental management systems and the implementation of any identified corrective actions and verification that all issues have been addressed properly.

By completing these steps, organizations can ensure that their EMS meets the requirements of ISO 14001:2015 and is effectively implemented. Additionally, they can identify areas where processes or procedures could be improved to ensure continued compliance with environmental regulations.

Finally, an EMS audit can provide valuable insight into the environmental performance of an organization, helping them make informed decisions about how to reduce their impacts on the environment and save costs in the long term.

The environmental management system requirements are set in place to help each organization established environmental objectives and internal audits to aid in proper business processes incase of an unplanned external audit.

In addition to identifying issues and providing recommendations for improvement, a successful ISO 14001 audit should include education and training for relevant personnel in implementing the necessary corrective actions.

This will help to ensure that any changes or improvements identified as part of the audit process are properly understood and put into practice effectively.

Furthermore, regular audits help to ensure that any non-conformances are addressed in a timely manner and that the organization remains compliant with all applicable regulations. By undergoing periodic EMS audits, organizations can demonstrate their commitment to environmental responsibility and sustainability.

What are the basic requirements of ISO 14001?

  1. Scope of the Environmental Management System

    The organization’s activities, products and services should be clearly stated in the scope of the EMS.

    This should include a description of the organization’s operations, processes, sites, departments, divisions, etc., to identify any associated environmental aspects or any adverse environmental impacts. Any legal or other requirements that must be addressed should also be specified.

  2. Environmental Policy

    The Environmental Policy outlines the organization’s commitment to protecting and enhancing the environment, as well as meeting all legal requirements.

  3. Evaluation of Environmental Risks and Opportunities

    Risks and opportunities should be identified, evaluated, monitored and managed in order to minimize the environmental impact of the organization or to identify any significant environmental aspects. This will involve collecting data relating to environmental performance indicators such as air quality, water usage, waste production and energy consumption.

  4. Evaluation of Environmental Aspects

    Businesses have a responsibility to put in place measures to reduce the environmental impacts of their activities. This involves assessing what impacts are created and putting in place sustainable practices that minimize or eliminate them.

    Examples of such practices include reducing energy consumption, waste minimization, reusing materials and resources, and exploring renewable energy sources. Additionally, businesses must stay abreast of environmental regulations and laws, as failure to comply with these can lead to substantial financial penalties.

  5. Environmental Objectives and plans for achieving them

    The environmental objectives of your organization should be realistic, achievable and measurable. They should also cover both short-term and long-term goals for the business.

    To ensure that these objectives are achieved, it is essential to have a structured plan in place with clear steps toward achieving each one as well as keep maintained documented environmental objectives for all relevant interested parties.

  6. Operational Control Procedures

    Organizations must take responsibility for setting their own operational controls to ensure that they meet the requirements of ISO 14001.

    The standard provides guidance on how organizations should go about this, including defining and documenting relevant internal procedures; assessing environmental objectives; conducting risk assessments; and identifying any training needs.

    When it comes to implementing these operational controls, organizations need to ensure that they are appropriate for the sector they operate in and take into account any relevant legal or compliance requirements.

    Furthermore, organization should review these controls regularly to ensure that they remain effective and address any changes in legislation or industry practices.

  7. Procedure for Emergency Preparedness and Response

    With an emergency plan, your organization will be able to respond appropriately and effectively in the event of an environmental emergency. A well-developed plan should include clear roles and responsibilities for staff, methods for communicating with stakeholders, and a system for evaluating the effectiveness of response measures.

  8. List of Interested Parties, Legal and Other Requirements

    In order to ensure a successful management system, it is essential that the needs and expectations of all interested parties are taken into account. Understanding these interests provides an insight into how the organization’s operations can contribute positively to the wider environment.

  9. Competence records

    Recording the training and competence levels of every member of your organization is an important part of introducing and managing an EMS. A successful EMS requires all staff to have a good understanding of their environmental responsibilities.

  10. Evidence of Communication

    Internal and External communications are also a key part of your management system. You can use external communications to inform people in the community or industry about your environmental objectives, progress reports on performance metrics, initiatives you have introduced and successes achieved.

    This will demonstrate to stakeholders that your organization is committed to environmental improvement and accountable for its actions.

  11. Monitoring Performance Information

    In order to demonstrate continual improvement, your organization must measure its performance and effectiveness in relation to the objectives of ISO 14001. It is important to have a record of these evaluations so that you can track the progress made toward achieving those objectives.

  12. Compliance obligations record

    It is essential to stay up-to-date with all legal environmental requirements that your organization is subject to. This can be achieved by carrying out a competent evaluation of applicable laws and regulations and conducting regular reviews to ensure the record is accurate and current. Additionally, it should also be documented any obligations your organization has to other parties.

  13. Internal Audit Program and Results

    A regular internal audit of your EMS is essential for its ongoing effectiveness and the overall environmental performance of your organisation. An audit can help to identify any issues or opportunities for improvement that have been overlooked, as well as demonstrate compliance with processes set up as part of implementing an EMS.

  14. Management Review Results

    The results of a management review should be used to identify areas for improvement, as well as any corrective and preventive actions necessary. Furthermore, senior management should also provide feedback on the effectiveness of corrective and preventive action taken in response to the review results.

  15. Nonconformities and Corrective Action

    It is important that root cause analysis is conducted to identify the source of the nonconformity. This should include a review of any relevant documentation, as well as an examination of processes and/or procedures which may have contributed to the issue. Once a root cause has been identified, corrective action can be taken to prevent recurrence and ensure compliance.

    The corrective action should be documented clearly in your records, including the specific steps taken to ensure the environmental management system conforms to the new policy.

    This should include details of any training or process modifications that have been implemented, as well as any changes to procedures and/or equipment used. You should also identify the individuals responsible for each stage of the process.

What are the 3 C’s of ISO 14001 EMS auditing?

  1. Conformance
  2. Consistency
  3. Continual Improvement

What are the mandatory records for ISO 14001?

The mandatory records of ISO 14001 include: Records of competence, awareness, and training.

These records are essential to your environmental management system, as they provide evidence that those involved in the system are adequately trained and aware of their responsibilities.

They demonstrate to regulators and other stakeholders that you have taken steps to ensure that everyone is well informed on how to reduce your environmental impact. Records may include details of courses attended, training materials such as manuals or handouts, and any assessments made about an individual’s knowledge or ability.

Additionally, these records should be regularly updated so that you can track changes in personnel and keep up with advances in technology or processes.

By maintaining a clear record of who has been trained, when they were trained, and what specifically was addressed during the training session(s), you will be able to ensure that all parties understand their roles and remain up-to-date on the latest regulations and best practices.

Additionally, these records provide a basis for continuing improvement in your environmental management system by allowing you to identify gaps or areas where more training may be needed.

How do I audit a ISO 14001 checklist?

In order to achieve ISO 14001 certification, organizations must first develop an environmental policy that contains a commitment to continual improvement and compliance with applicable laws.

The organization must also create objectives and targets for their EMS. These should be aimed at reducing the company’s negative impact on the environment and can include such areas as energy efficiency, waste management, water conservation, emissions control, and pollution prevention.

The next step is to assess any existing environmental impacts of the organization’s operations. This assessment should identify risks or opportunities associated with environmental issues in order to develop mitigation strategies or take advantage of potential benefits.

Once these steps are completed, the organization needs to develop procedures related to all aspects of their environmental activities. These procedures ensure that employees are aware of their responsibilities and know how to handle environmental issues. The organization must also put in place a system for monitoring, measuring, and evaluating the performance of its EMS.

Finally, organizations must provide training to employees on the content covered by their environmental policy and procedures. They should also strive to continually improve their EMS by setting new goals or expanding upon existing objectives.

Doing so will help them maintain ISO 14001 certification while also reducing their negative impacts on the environment.

In summary, ISO 14001 provides organizations with an internationally recognized framework for designing, implementing, and improving an effective environmental management system that can be certified for.

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Sustainability Consulting for the 21st Century

Sustainability Consulting for the 21st Century

The modern world is a sustainable one. It’s time for your business to join the ranks of those who are making a difference.

Sustainability has become one of the most important topics of our time. As the world becomes more and more aware of the environmental, social, and economic challenges we face, more and more businesses are looking for ways to operate in a more sustainable way.

That’s where sustainability consulting comes in. A sustainability consultant helps businesses identify opportunities to operate in a more sustainable way. This can mean anything from reducing energy consumption to increasing employee engagement in sustainability goals.

Sustainability consultants come from a variety of backgrounds, but all share a common goal: to help businesses move towards a more sustainable future with sustainability services.

The good news is that sustainability consulting is one of the fastest growing industries in North America and the world. The bad news is that it can be hard to know where to start when it comes to finding a sustainability consultant that’s right for your business.

Here are four tips to help you find the right sustainability consultant for your business:

1. Define your sustainability goals and ESG strategy.

What does your business want to achieve by working with a sustainability consultant? Do you want to reduce your carbon footprint in your global business? Develop more robust sustainability strategies? Achieve sustainable development goals? Incorporate sustainability solutions and a sustainable infrastructure into your business strategy? Improve employee engagement? Need risk management? Find ways to save money.

Once you know what you want to achieve, you can start looking for consulting firms that specialize in those areas.

2. Identify a budget.

Do your sustainability ambitions match resources available for the project? Does the ESG (Environmental Social and Governance) strategy align with your corporate growth strategy?

It is recommended to present a sustainability strategy internally, that outlines tiers of investment and the types of sustainability performance to be expected per expenditure.

3. Do your research.

Do a deep dive in the sustainability consulting services universe. Once you’ve identified some consulting firms that might be a good fit, take some time to learn about their backgrounds and experience and nail it down to your favorite consulting firm.

How long have they been working in a sustainable business? What are some of the clients they’ve worked with? What do other people say about them? Top consulting firms offer diverse corporate responsibility solutions and professional services across a wide swathe of industry sectors.

4. Ask for recommendations.

Talk to other businesses in your industry and see if they’ve worked with any sustainability consulting firms that they would recommend. If you know someone who works in sustainable business, ask them for their thoughts on different consultants.

The best way to find a good consultant in the large world of the consulting industry is through word-of-mouth from people who have worked with them before.

A global management consultancy will have the general pulse on corporate social responsibility. Top sustainability consulting firms will be a global leader in change management and integrated business planning.

The best ones possess deep expertise in the management of business risk and climate risk, while working with you to embed sustainability into your culture.

These days, there’s no excuse for not being sustainable, not manage risk, and not create sustainable business models.

Future leaders and businesses that don’t take steps to operate sustainably will not only be missing out on opportunities and losing business value, but will also be left behind as society progresses towards a more sustainable future.

These can be complex problems. Sustainability consulting is one of the best ways for businesses to make sure they’re operating sustainably and making a positive impact measurement on the world around them.

iSi Environmental is a leading provider of environmental consulting and management consulting services in the United States and we are committed to protecting the planet and its inhabitants with the skills and knowledge of our people. With us you get long term value.

Senior Executives and Sustainability Teams turn to us when:

  • Their team is short on time and resources to achieve organizational sustainability strategy
  • They need hands-on implementation of new compliance processes
  • They need to integrate sustainability at multiple locations
  • Also turn to us when looking to roll local best practices into a global corporate system

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