Those who work in high hazard industries are familiar with the OSHA Process Safety Management (PSM) and EPA Risk Management Plan (RMP) requirements for routine audits to assess and verify compliance with these regulations. Completion and follow-up on findings from audits are an important element for continuous improvement and regulatory compliance. The Challenges Routine audits are an important element of regulatory compliance. A quality audit is based on specific regulatory requirements and related Recognized And Generally Accepted Good Engineering Practices (RAGAGEP), with an adequate review of site processes and evidence for each of the requirements. Evidence reviews don’t mean that every single item of evidence is reviewed, but that a suitable and typically random range of evidence is thoroughly reviewed to determine if there is a pattern of compliance or non-compliance. Then, if justified, findings and recommendations are developed against specific requirements. Depending on company expectations, recommendations may also be developed to help bring site processes in line with industry best practices. The Stakes A variety of staffing strategies for completing PSM and RMP required audits are possible, including those handled by site personnel, those handled by company personnel independent of the audit site, and those conducted by personnel with external companies. Based at least partly on who conducts an audit and their relationship with the site, a variety of audit outcomes are possible. Reports and findings or recommendations that are so comprehensive (even overly picky at times) are more common than you might think. This type of audit, if unchallenged by the site, may drive expending excessive resources on PSM and RMP system improvements that may or may not be truly needed. At the other end of the spectrum, “check the box” audits are also more common than you may think. This type of audit and report may be so lacking in-depth review that they might lead a site to believe that their PSM and RMP systems are fine and need few or even no improvements, even when that’s not true. In one case, you may over-invest in changes that may or may not drive improvements that are really needed; and in the other case, you may under-invest and have a false sense of confidence in your systems to manage risk. Neither case is desirable from a business perspective. So What? Who should conduct your PSM and RMP audits to have the best probability of an outcome that will drive truly necessary site improvements? This question is best answered by each organization and should be based on site and corporate goals and expectations for their regulatory compliance. Review by external auditors with wide-ranging experience has proven at many sites to provide the best-case outcome of an audit, resulting in findings and best practice recommendations that drive true compliance with right-sized resource needs. In many cases, external auditors can also offer specific methods and techniques for efficient and speedy resolution of concerns identified at sites. Their range of experience enables external auditors to share the general methods proven to drive good PSM and RMP compliance across industry. Companies that have lean or less-experienced workforces or that are unsure where they stand versus industry norms for PSM and RMP compliance may benefit from engaging a firm with experienced auditors. This independence from the site and company has the best probability of a careful assessment with fresh eyes on the relevant critical systems and leads to efficient compliance with the necessary standards.

According to the World Robotics 20211 reports, published by the International Federation of Robotics (IFR), South Korea, Singapore, Japan, Germany, and Sweden are the most automated countries in the world. While the U.S. lags behind, it is rapidly picking up pace as technology advances and organizations search for solutions to labor shortages. We live in a time where automated manufacturing is gaining momentum and robot integration is becoming more popular in the sector, with new robot applications invented daily. However, just as robotics exhibit a tremendous potential for applications, they also represent a tremendous potential for risk of injury. As part of the machinery safety lifecycle, a robotics system Risk Assessment (RA) identifies the proper risk-reduction safeguards to reduce the high level risks (e.g., crushing, shearing, trapping, striking) that are associated with certain robotic operational scenarios. The robot user – which is typically the employer – is responsible for the safety of the plant; therefore, it is of utmost importance that an application-specific and site-specific RA is carried out by the robot user. One of the horrific examples of past robot accidents has been published in the OSHA Technical Manual Section IV: Chapter 4, where a worker accidentally tripped the power switch while another worker was servicing an assembly robot. As a result, the robot manipulator struck the maintenance worker’s hand, resulting in a severe injury. This would have been prevented if a RA had been conducted through identifying the need for proper lockout/tagout to prevent repowering the assembly robot, relocating the power switch since it was easy to inadvertently change its power state, or ensuring the application met electrical safety standards. An effective RA starts with including knowledgeable employees with expertise in the operations, specific robotic application, RA methodology, and any specialized experience. The assessment team identifies all of the tasks to be performed as part of the robot operations and maintenance, with special attention given to any tasks that may be particularly hazardous or complicated. RAs are completed for hazardous situations associated with each stage of the robot development (i.e., assembly, integration, operation, and maintenance). The potential for harm and likelihood of occurrence of each hazardous situation is identified along with the most appropriate risk reduction technique. The documented RA is distributed to and accepted by the team and all affected employees, ensuring that all personnel involved with the robot operations and maintenance understand the associated hazards and safeguarding. Furthermore, similar applications within the same plant should each have their own individual robotic system RAs, analyzed on an application-specific and site-specific level. Although the equipment may be of the same make and model, the robot applications may work on different parts or processes, be integrated into different upstream and downstream equipment, or perform unique automated functions that expose workers to particular hazards. Additionally, a robot’s end-effector, programming, or physical placement in the facility may be different from another robot with otherwise identical characteristics, which must be properly and individually analyzed for the potential for serious injury and risk mitigation. Safeguards must be tailored specifically to protect against each hazardous situation, meeting the organization’s safety requirements and those dictated by industry consensus standards. Preferred safeguards may change based on the application and on the robot user’s risk tolerance. For example, the access frequency, orientation of the robot within a facility, and organizational disposition may dictate whether the preferred safeguard for access to the robotic cell is an interlocking gate or presence-sensing device, and whether or not the robot is designed and programmed to reset automatically. The RA defines the required safety functions and safety requirements specifications, both of which depend on the application. The RA team develops the safety system design requirements and selects the safeguards to perform each safety function. ANSI/RIA R15.06 Safety Requirements for Industrial Robots and Robot Systems provides detailed steps for conducting a task-based RA to conform with the industry consensus standards and includes examples that apply to many common robot applications. The IFR estimates that there were more than 2 million robots in the worldwide workforce at the end of 2018, which continues to increase yearly as robotic systems appear in even more industries. As more workers become exposed to robots, assuring compliance with industry consensus safety standards is of paramount importance as a means of reducing the risk of injury associated with robot interaction. An application-specific, site-specific RA identifies the hazards, risks, controls, and safeguards that apply towards the proper safety system design. The robot user is responsible for plant safety, which is why it is imperative that the user ensures that the RA is properly performed. aeSolutions offers robotic risk assessments and can provide expert guidance and training to help you effectively perform an application-specific, site-specific RA for your robotic systems. 1. The International Federation of Robotics. Executive Summary World Robotics 2021 Industrial Robots. 2021, ifr.org/img/worldrobotics/Executive_Summary_WR_Industrial_Robots_2021.pdf

Guidelines for a Safety Instrumented BMS Design by Shahid Saeed, CFSE Fired equipment such as industrial boilers, incinerators, process furnaces, and fluid heaters are used everywhere. They are a crucial, complex, and integral part of the industrial operations and therefore require a meticulous approach to the design, operation, and maintenance of their associated safety systems. Although some detailed and prescriptive guidelines for designing safety systems, such as a Burner Management System (BMS) for combustion safety of fired equipment, have been around for many years, the rate and degree of adoption varies significantly within the industry. Most operating companies have their own practices, which may vary from facility to facility or even within the same facility. In addition, for each installation, it is not unusual for adjacent fired equipment built two years apart to have a different BMS design, simply because either they are obtained from different Original Equipment Manufacturers (OEMs), or different engineering contractors built them. With increasing government legislation and regulations, as well as mounting lawsuits for accidents, these inconsistencies can become a challenge for operations and maintenance personnel to operate their fired equipment safely and reliably. One solution is to standardize the BMS design for combustion safety of the fired equipment. The standardization for BMS design, operation, and maintenance of the fired equipment requires a holistic approach considering all aspects of combustion safety, including compliance with applicable National Fire Protection Association (NFPA) or American Petroleum Institute (API) prescriptive codes/standards (NFPA 85, 86, 87, or API 556), performance criteria for achieving design objectives, fuel train, field devices, logic solver platform, control panel, startup sequences & shutdown interlocks logic, Human Machine Interface (HMI) displays, Combustion Control System (CCS) interaction, training, operation and maintenance procedures. A brief description of these aspects is given below: 1. Perform a compliance check for the BMS of fired equipment (specifically brownfield) against applicable prescriptive codes/standards (NFPA 85, 86, 87, or API 556). The compliance check needs to look at all applicable requirements, for example, manual emergency shutoff valve at a safe location, manual equipment isolation valve, sediment trap (drip leg), filter (Y-strainer), separation as well as location of vents, proof of closure switches and means for leakage testing of safety shutoff valves, etc. which will help in standardizing the fuel train and field devices for different fired equipment using the same type of fuel and burner draft configuration (i.e., natural draft, forced draft, induced draft, and balanced draft). 2. Treat the BMS for the fired equipment as a Safety Instrumented System (SIS) application and apply the SIS safety lifecycle concepts following the industry consensus performance-based standard (ANSI/ISA 61511:2018 or IEC 61511) for achieving the BMS design objectives. A Safety Instrumented-BMS (SI-BMS) design process involves the following steps: a) Perform a Process Hazard Analysis (PHA) such as Hazard and Operability (HAZOP) study to identify the potential hazards related to the fired equipment operation. b) Apply Layers of Protection Analysis (LOPA) commonly used risk assessment technique to determine existing Independent Protection Layers (IPLs) in preventing the potential hazards. It will also identify whether there are deficiencies in the existing design requiring new IPLs for closing the determined risk level gaps between the current risk and the tolerable risk of the potential hazards. c) Identify Safety Instrumented Functions (SIFs) and select their target Safety Integrity Level (SIL) to close the LOPA gaps of the hazardous scenarios. d) Perform SIL verification calculations of SIFs using approved & certified SIS logic solver, field devices, and desired test interval to calculate the achieved SIL and verify that it meets the target SIL of each SIF. e) Develop Safety Requirements Specification (SRS) to provide SIF integrity and functional requirements, including cause & effect diagram, sequential function charts, and BMS instruments list. f) Develop Proof Test Procedures (PTPs) for performing regular functional testing of the SIFs based on the desired test interval. g) Perform Functional Safety Assessment (FSA) at specified stages of the SIS safety lifecycle. The above activities and corresponding deliverables can be standardized for different fired equipment having common hazardous scenarios. For example, loss of flame due to inadequate air-fuel ratio and inadequate purge during startup are typical common hazards applicable to single, fuel gas-fired, and forced draft burners used in different fired equipment. 3. Standardize the fuel train & field devices based on client’s approved, IEC 61508 certified (SIL rated) and/or listed for combustion safety service to achieve a consistent BMS solution for different fired equipment. 4. Select BMS logic solver platform certified to IEC 61508 for SIL 2 or greater and approved by the client for the BMS control panel to achieve a standard BMS for different fired equipment. 5. Implement BMS logic related to startup sequences and shutdown interlocks (SIFs & non-SIFs) using standard and approved function blocks to achieve BMS logic consistency for different fired equipment. 6. Develop standard HMI displays with ease of use providing all required information for the startup, normal operation, shutdown, and troubleshooting of the BMS for different fired equipment. 7. Implement seamless CCS interaction and required control for proper functioning of the startup sequences and shutdown interlocks using typical interface signals (e.g., Purge Request) for BMS of different fired equipment. 8. Conduct trainings for operation and maintenance personnel on startup, normal operation, shutdown, and troubleshooting of the standard BMS 9. Update and/or develop operation and maintenance procedures to achieve consistency regarding BMS operation and maintenance By standardizing a BMS design, operations and maintenance personnel can translate their skills and knowledge about combustion safety of one fired equipment to multiple types of fired equipment installed within the same facility or different facilities. This can drive consistent practices and improve the quality of work (e.g., by minimizing human factors), resulting in safer and more reliable operations. It is also more sustainable in the sense that the extent of training may be reduced – operators may not need to be trained on every individual fired equipment with consideration to differences in design and procedure, and the standardization would provide greater clarity to newly hired employees. Maintenance costs could also be minimized if there are common spare parts for the instrumentation & logic solver of the standard BMS, rather than needing separate spare parts for the non-standard BMS of the fired equipment. There are multiple levels of safety benefits, operational efficiencies, and cost savings. Despite the possible benefits, there can be resistance to changing a fired equipment’s existing BMS to a standardized BMS design. Operating companies may contend that they have been operating the fired equipment for many years without any incidents or issues, but that should not necessarily suggest it is safe. There could be unknown issues that simply have not been revealed or identified yet. Brownfield fired equipment needs to be evaluated against latest industry codes/standards to reveal potential gaps, accompanied by proactive steps to ensure the fired equipment is properly operated and maintained. Some existing instrumentation and logic solvers of the BMS are becoming unavailable as manufacturers go out of business or no longer produce obsolete parts, so proactive replacement measures may prevent aging components from failing. In addition, the existing BMS instrumentation and logic solver lack built-in diagnostics, alerts, and functionalities essential for the safe operation and maintenance of the fired equipment. Operating companies might also believe that their operations and maintenance personnel are already trained on the existing BMS and procedures, but this may not be the case with older systems that are poorly documented. The benefits of standardizing BMS design for fired equipment are a worthwhile investment to avoid potential future safety incidents and related financial impacts. Standardizing BMS for combustion safety of the fired equipment has both short and long-term benefits. In the short term, standardization can drive consistency and save on training, operational, and maintenance costs. In the long term, applying the SIS safety lifecycle concepts to standardize the combustion safety via the SI-BMS approach ensures that fired equipment follows Process Safety Management (PSM) regulations as defined by Occupational Safety and Health Administration (OSHA) and ultimately provides operating companies with safe, reliable, and resilient industrial operations. Biomass station image used: Bava Alcide57 at English Wikipedia, CC BY-SA 3.0

Following on from the first three aeSolutions blogs on the subject of combustible dust concerns, this blog provides another deep dive into the topic. We previously addressed the basic concerns around combustible dusts, many of the standards that address dust hazard guidance, and the properties and testing for combustible dusts; and potential ignition sources. Pt1. ​Do You Know the Basics? Pt2. Dust Properties and Dust Hazard Signs Pt3. Dust Ignition Sources This article will build on those topics to address potential safeguards for dust fires and explosions for both internal and external dust clouds or layers. A later blog in this series will pull it all together and review commonly used dust hazard assessment (DHA) methods. Dust Handling Safeguards As previously described in this series, dust flash fires and explosions can have extremely serious safety, environmental, financial and reputational consequences. As you would expect for any potentially serious process safety consequences, there is a range of possible safeguards including both administrative and engineering controls. Control of ignition sources is the first and most obvious family of safeguards and it includes both administrative and engineering techniques: Proper grounding and bonding of equipment using both the NEC and NFPA 77 (Recommended Practice on Static Electricity) is a fundamental requirement. To provide assurance that the grounding and bonding system remains in good order, a routine ground inspection / assurance program, e.g., grounding system and piping/ducting strap inspection program, should be implemented in accordance with NFPA 654. Temporary grounding arrangements for loading or unloading of dusts require special attention to make sure of the integrity of frequently operated clamps and the operational discipline to use them every single time. For some dusts with low minimum ignition energy, use of personnel grounding may be considered (e.g., static-dissipating shoes and special conductive flooring). Continuing with the engineering controls, proper electrical area classification using the guidance in NFPA 499 (RP for Classification of Combustible Dusts and of Hazardous Locations for Electrical Installations). Proper area classification is important to minimize potential for sparks and to keep equipment surface temperatures below the ignition temperatures for a given dust. One of the most critical aspects of establishing Class II areas for dusts is selection of the temperature class for equipment. It is very important to have firm knowledge of the dust’s minimum auto-ignition temperature (MAIT), layer ignition temperature (LIT), and maximum rate reaction initiation temperature (if applicable) to correctly establish the required temperature class. Minimizing the possibility for equipment to produce sparks due to mechanical malfunctions is another important aspect of ignition control. Mechanical spark sources include equipment parts rubbing together creating friction heat or sparks, bearing failures, lack of lubrication and similar issues. A strong mechanical integrity program in accordance with manufacturer recommendations is important. This includes routine tasks such as a routine lubrication program, power and/or vibration monitoring, and temperature monitoring in some cases. A written program is an important tool to initiate and maintain a strong mechanical integrity program. Keeping stray metal (often called “tramp metal”) out of processing equipment is important due to the potential for mechanical sparking and frictional heating; exclusion of tramp metal may require a combination of administrative and engineering measures. Whenever equipment is opened, there should be a visual inspection just prior to closing to ensure no metal items, such as tools, filings, nuts, etc., are left behind. In some cases, where incursion of metal from upstream sources is credible, filtering prior to during steps is advisable. Control of hot work is a very important administrative tool to minimize the potential for hot work to generate sparks or open flames when dust may be present. NFPA 51B Standard for Fire Prevention During Welding, Cutting, and Other Hot Work is a good resource for hot work program development. An inherently safer method for dust explosion potential is to provide equipment designed for the maximum explosion overpressure (Pmax). Pmax is typically 8-9 times the initial absolute process pressure, so this can be a good solution for cases where the normal process pressure is near atmospheric. Care needs to be taken in consideration of “pressure piling” at interconnected ducting and equipment, since those pressures can be substantial, and it may be impractical to design for the higher pressures that may be expected at interconnected equipment. NFPA 69 Standard on Explosion Prevention Systems includes design information on this topic. A concept called deflagration isolation is sometimes used to prevent propagation of an explosion and the pressure piling at connected equipment that may go with it. Deflagration isolation systems may include rotary valves, flame arrestors, fast acting automatic valves which close on a rapid pressure increase, and others. Reducing the oxygen concentration internal to dust-handling equipment to below the limiting oxygen concentration (LOC) for the dust is a great method to prevent ignition if it is feasible for your system. Many facilities use nitrogen for this purpose and manage the system as safety-critical. If selected, the oxygen concentration of the conveying gas should be specified at a safe margin below the LOC. Somewhat related to control of oxygen content, the concentration of dust may at times also be controlled to significantly below the minimum explosible concentration (MEC) for the dust. Concentration control may not always be practical from a commercial standpoint as it may limit production rates. In cases where the conveying gas is not below the LOC, a mitigating safeguard to quench explosions in progress is sometimes specified. Nitrogen suppression systems will open very quickly based on fast-acting change of pressure switches. A rapid inflow of nitrogen may quench an imminent explosion internal to equipment. Proper sizing, numbers, and locations of the nitrogen cannisters is of crucial importance. The suppression system also has to act faster than the time for the development of the explosion. Specialist personnel should be engaged to handle the detailed design of suppression systems. Deflagration vents are another potential mitigating system which act to reduce the explosion pressure by venting it, similar to a rupture disc. Deflagration vents may be installed on equipment and on buildings where the potential for dust explosions is present. Deflagration vents can be quite large, depending on the application and should be vented to a safe location. NFPA 68 Explosion Protection by Deflagration Venting includes design information on this topic. A buildup of dust layers internal to equipment is a concern due to the potential for high surface temperature or a maximum rate reaction to ignite the layer. The primary control for this concern is an effective manual or automatic cleaning regime in place for equipment subject to internal layer buildup, including routine inspections to verify adequate cleaning. Supervisory signoffs and audits of this activity are also a good practice. External leakage of dust is a concern that needs to be addressed, as it may result in either dust explosions (if leakage is above the minimum explosive concentration (MEC) or dust fires in the case of layer buildups. There is a two-pronged safeguarding approach to address leakage. First is a strong mechanical integrity program which addresses typical leakage points proactively. Second is a strong housekeeping program in which incipient leaks are rapidly addressed, which should be supplemented by a strong routine housecleaning culture which allows for prompt cleanup of leaked dust. Similar to the internal dust layer concern, Supervisory signoffs and audits of housekeeping are also a good practice. The routine review should include all flat surfaces in the facility, including those which may not be perfectly visible, e.g., tops of equipment and tops of structural members. Building fire suppression systems are a sensible precaution to mitigate dust explosion consequences but as they are a post-explosion mitigating system, they are not typically regarded as a strong protection in these cases. The Stakes Do you handle potentially combustible dusts at your site? It is difficult to adequately control a hazard that is not well-understood, and no company wants to learn of dust explosion hazards the hard way. How do you know if you have sufficient safeguards present for combustible dust hazards at your facility? A Dust Hazard Analysis (DHA) and careful review of the engineering and administrative safeguards in place is the clear answer. So What? If you have not previously taken a deep dive into the safeguards in place for your particular dust(s) ignition sources at your site, now would be a good time to do so. If you do not have the right technical expertise in your company to assess dust hazards, ignition sources and safeguards, consider selecting a process safety consultancy with deep experience and expertise to assist you. Their range of experience enables assessors to recommend reputable testing labs and to share the general and specific methods proven to minimize dust explosion hazards across industry. This independence from the site and company has the best probability of a careful assessment with fresh eyes on the relevant critical systems and leads to more efficient compliance with the necessary standards. Stay tuned for more. A later blog in this series will address commonly used dust hazard assessment (DHA) methods.

by Judith Lesslie, CFSE, CSP This is the second in a series. You can find the first here. Following on from the first aeSolutions blog on the subject of the basics of combustible dust concerns, this blog provides a deeper dive into the properties of combustible dusts. It is necessary to first understand your specific dust testing and properties to assess the potential hazards of a given dust handling process. A past blog provided an overview of the generalities of combustible dust hazards, including some serious past incidents, and provided some of the relevant guidance documents for those who are interested in more detailed information. Once the article’s technical basis is understood, future blogs will cover signals that there may be previously unrecognized dust hazards at your site, common ignition sources and safeguards, and potential dust hazard assessment (DHA) methods. Combustible Dust Properties Technical definitions of combustible dust vary only slightly across industries and agencies. OSHA, for example, defines it as "a solid material composed of distinct particles or pieces, regardless of size, shape, or chemical composition, which presents a fire or deflagration hazard when suspended in air or some other oxidizing medium over a range of concentrations". The NFPA defines it as “a finely divided combustible particulate solid that presents a flash-fire hazard or explosion hazard when suspended in air or the process-specific oxidizing medium over a range of concentrations” (NFPA 652, 2019). The CCPS defines it similarly to the NFPA (CCPS Guidelines for Combustible Dust Hazard Analysis, Wiley, 2017). So what are the parameters of interest when it comes to deciding whether or not a dust presents a combustibility or explosion hazard? There are a number of relevant parameters that can be determined through testing per various ASTM, EN and IEC standards, including: An initial explosivity screening test, which disperses dust samples in a chamber at various concentrations and exposes them to an ignition source, then determines the resulting pressure rise. If the standard pressure rise is by more than a factor of 2, then more detailed testing is indicated. Deflagration index testing (Kst, given in units of bar-m/sec) measures how quickly pressure rises in a closed container when ignited. Kst is used to classify the dust hazard at St. 1, 2 or 3. Kst, of 0-200 is St. 1 (lowest hazard), 201-300 is St. 2 and greater than 300 is St. 3 (highest hazard). However, “low” is deceiving in this context. For example, the Kst of sugar (the dust involved in the serious dust explosion incident mentioned in a previous blog) is about 138. There have been numerous other serious explosion incidents from low Kst dusts as well. OSHA considers a Kst of 1.5 bar-m/sec as the minimum threshold for an explosion. Maximum pressure testing (Pmax, given in units of bar) provides the peak explosion pressure developed by a dust explosion at its optimal concentration. Pmax is helpful in identifying potential worst-case equipment and compartment consequences due to a dust explosion; and is used in vent, explosion panel and explosion containment designs. Minimum explosible concentration testing (MEC, given in g/m3) provides the minimum concentration of a dust that will deflagrate. The MEC is helpful in defining potential damage as well; and is also very useful if a site plans to use concentration control as a safety measure. Minimum ignition energy testing (MIE, given in mJoules) provides the minimum electrical energy stored in a capacitor, which, when discharged, is sufficient to ignite the most ignitable mixture of dust. MIE is useful for evaluating what sources of ignition energy are credible to ignite a dust cloud. One item to be aware of for MIE is that it is typically determined at standard temperature and pressure conditions; and the MIE may be expected to be somewhat lower at higher actual process temperatures. Limiting oxygen concentration testing (LOC, given in vol% O2) provides the minimum concentration of oxygen in a mixture of dust, air and an inert gas that will support combustion. This information is useful when considering the design of explosion prevention systems involving the use of inert gases. Minimum auto-ignition temperature testing (MAIT, degrees C) provides the lowest surface temperature that will auto-ignite a given dust cloud. MAIT is useful for evaluating equipment and process temperatures to minimize the risk of auto-ignition. The remaining parameters are conducted on dust layers or bulk samples rather than dispersed samples: Volume (or bulk) resistivity testing (ohm-m) provides the electrical resistance of a solid material. It is useful when assessing the insulating and electrostatic properties of a material, and hence the potential for a material to generate and retain charge. Higher resistance dusts have the potential for charging during material handling (including loading activity) and releasing electrostatic charges. This is a concern if the energy of the electrostatic charge may exceed the minimum ignition energy for the dust under the operating conditions. Layer (or hot surface) ignition temperature testing (LIT, given in degrees C) provides the lowest surface temperature capable of igniting various thicknesses of a dust layer, such as buildup that could occur in dyers, classifiers, or packaging equipment. LIT is used together with MAIT to evaluate equipment and process temperatures to minimize the risk of auto-ignition in dusty areas and equipment. Time to maximum rate/exothermic reaction at a given temperature testing (usually provided as a set of temperatures and times of interest) is a less obvious concern. Some dusts are capable of self-heating in an exothermic reaction if allowed to persist in a layer above the maximum rate onset temperature for long enough. The maximum rate reaction can produce smoldering, fire and combustion products that can be carried along in a moving particle stream and become a source of ignition. If a dust has this property, it can also cause development of toxic or flammable gases, depending on the process and conveying gas. The information provided through maximum rate testing is highly relevant to cleaning of dust layer buildups, process temperatures, equipment temperatures and housekeeping regimes to minimize dusting around process equipment. The bottom line is that even dusts with weak explosivity and high ignition energy requirements can be dangerous under the right circumstances. The right circumstances include: · Presence of fuel, e.g., combustible dust · Presence of oxygen · An ignition source (including hot surfaces) · Dispersion of the combustible dust · Confinement of the combustible dust cloud The dispersion and confinement factors above are specifically required for dust explosions. Without the presence of confinement, a dust cloud flash fire is possible. There will be more on this topic in this continuing series. Stay tuned! The Stakes Do you handle potentially combustible dusts at your site? It is difficult to adequately control a hazard that is not well-understood, and no company wants to learn of dust explosion hazards the hard way. How do you know if you have combustible dust hazards present? Screening and testing of a representative sample of the dust for the parameters noted above is the clear answer. This type of testing is available from many reputable labs and suppliers and can even be coordinated on your behalf by reputable process safety consultancies. So What? If you have not previously taken a deep dive into the properties of your particular dust(s) at your site, now would be a good time to do so. If you do not have the right technical expertise in your company to assess dust hazards, consider selecting a process safety consultancy with deep experience and expertise to assist you. Their range of experience enables assessors to recommend reputable testing labs and to share the general and specific methods proven to minimize dust explosion hazards across industry. This independence from the site and company has the best probability of a careful assessment with fresh eyes on the relevant critical systems and leads to more efficient compliance with the necessary standards. Stay tuned for more. Future blogs in this series will cover signals that there may be previously unrecognized dust hazards at your site, common ignition sources and safeguards, and potential dust hazard assessment (DHA) methods. Part 3: Dust Ignition Sources

by Judith Lesslie, CFSE, CSP Those who work in high hazard industries are familiar with the OSHA Process Safety Management (PSM) and EPA Risk Management Plan (RMP) requirements for routine process hazard analyses. Potentially less well known is the variety of additional guidance for specific chemical hazards, such as combustible dusts. Guidance available for assessing the risk of combustible dust incidents is available via OSHA guidance, a national emphasis program (NEP), technical manuals, and interpretation letters; and industry standards for the fundamentals of and prevention of dust explosions. This blog will provide a general overview of combustible dust hazards, including serious past incidents, and provide information on some of the relevant guidance for those who are interested in more information. Future blogs on the subject of combustible dusts will review relevant dust properties, signs that a dust hazard may be present in a process, common ignition sources and safeguards, and potential dust hazard assessment (DHA) methods. The Challenges Companies handling highly hazardous chemicals (HHC) routinely conduct process hazard analyses (PHAs) and often have internal standards and methods for facilitation involving internal and/or external facilitation. It is less common to encounter PHAs that thoroughly cover dust hazards or company internal standards that address combustible dust hazards. Many companies’ PHAs do not address combustible dust hazards in an organized manner or in a manner that complies with NFPA guidance on dust hazard analyses (DHA) if the hazards are covered at all. Even worse, for processes not subject to the PSM and RMP standards, routine PHAs or DHAs may not be conducted at all. This is a potentially dangerous miss in a variety of manufacturing processes. Why? Because combustible dust explosions are highly credible when processes are not properly safeguarded, with the potential to result in catastrophic events, including loss of lives, serious disabling injuries, environmental damage, and major commercial costs from equipment and building damage and loss of production. Ignition sources range from various types of sparks generated by movement of dust, including via insulated, non-grounded or plastic storage containers; mechanical sparks such as from malfunctioning blowers or “tramp metal” present in the dust-handling process; electrical sparks from equipment malfunctions; and hot surfaces exceeding the auto-ignition temperature of the dust, as may occur with equipment malfunctions or maximum rate/exothermic reaction onset temperatures from product layer buildup. The US Chemical Safety Board (CSB) identified nearly 300 combustible dust incidents between 1980 and 2005, collectively involving 120 deaths, 718 injuries, and major damage to facilities. There are also more recent events. For example, there was a major sugar dust explosion and fire in 2008 at a Georgia sugar mill that resulted in 14 deaths and many serious injuries; and other recent serious incidents in industries as diverse as HHC and non-HHC chemical processes, food waste recycling, wastewater sludge handling, coal dust handling, metal-handling, paper mills, wood chipping and sawmills, and grain handling. Combustible dust explosions have generated substantial regulatory and industry standards activity in recent years resulting in a set of requirements and guidance documents that put users in a much better position to identify, understand and control their combustible dust hazards. Some of the major sources of information include: OSHA Hazard Communication Guidance for Combustible Dusts (OSHA 3371-08), 2009 OSHA Technical Manual – Section IV, Chapter 6, Combustible Dusts, Directive TED-01-00-015, effective date 2/10/2020 OSHA Combustible Dust National Emphasis Program (Reissued) (OSHA CPL 03-00-008), 2008 NFPA 652, Standard on the Fundamentals of Combustible Dust (2019). This document provides combustible dust technical basics, general requirements, hazard identification and other topics; and it directs users to industry/commodity-specific guidance documents, including: NFPA 61, Prevention of Fires and Dust Explosions in Agricultural and Food Processing Facilities, 2020 NFPA 484, Combustible Metals, 2022N FPA 654, Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids, 2020 NFPA 664, Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities, 2020 NFPA 68 Standard on Explosion Protection by Deflagration Venting, 2018 NFPA 69 Standard on Explosion Prevention Systems, 2019 NFPA 499, Recommended Practice for the Classification of Combustible Dusts and of Hazardous (Classified) Locations for Electrical Installations in Chemical Process Areas, 2021 FM Global Safety Data pamphlet FM 7-76, Prevention and mitigation of combustible dust explosion and Fire, interim revision 2020 The Stakes Do you handle potentially combustible dusts at your site? It is difficult to adequately control a hazard that is not well-understood. Even if you have a good-quality PHA, it may not delve deeply enough into the combustible dust topic in accordance with NFPA 652. NFPA 652 states that existing processes and compartments (e.g., building compartments) shall have a completed Dust Hazard Assessment (DHA) by September 7, 2020 (parag. 7.1.1.2) and that the DHA shall be reviewed and updated at least every five years (parag. 7.1.4). Are you in compliance? Are you positive your site is managing its combustible dust risks in all phases of operation well enough to prevent a serious explosion? While this standard is not legally binding at this time, OSHA inspectors have been encouraged to use NFPA standards to identify dust safety issues; and the General Duty clause requires employers to provide a workplace “…free from recognized hazards…”. Lack of a DHA or a poor quality DHA places sites at risk of an OSHA violation under the General Duty Clause. So What? If you have not previously taken a deep dive into the properties and hazards of your particular dust(s) and completed a DHA at your site, now would be a good time to do so. If you do not have the right expertise in your staff to assess dust hazards, consider selecting a process safety consultancy with deep experience and expertise to assist you. Their range of experience enables assessors to share the general and specific methods proven to minimize dust explosion hazards across industry. This independence from the site and company has the best probability of a careful assessment with fresh eyes on the relevant critical systems and leads to more efficient compliance with the necessary standards. Future blogs on the subject of combustible dusts will review important dust testing needs and properties, signs that a dust hazard may be present in a process, common ignition sources and safeguards, and potential dust hazard assessment (DHA) methods. Part 2: Dust Hazards – Dust Properties and Dust Hazard Signs

by Melissa Langsdon Ensuring safety is of utmost importance to industries managing hazardous materials and processes. Two crucial regulatory frameworks, the Environmental Protection Agency’s (EPA) Risk Management Program (RMP) rule and the Occupational Safety and Health Administration’s (OSHA) Process Safety Management (PSM) standard, are central to this effort.  For businesses operating in relevant industries, understanding the difference between EPA’s RMP and OSHA’s PSM requirements is essential. In general, PSM was established to protect the workplace inside the facility while RMP implemented to protect the environment and the community outside the facility. To help ensure safe and healthful workplaces, OSHA issued the Process Safety Management of Highly Hazardous Chemicals standard (29 CFR 1910.119), which contains requirements for the management of hazards associated with processes using highly hazardous chemicals (HHCs). The RMP rule, established under the Clean Air Act Amendments of 1990, falls under the purview of the Environmental Protection Agency (EPA) to regulate facilities with threshold quantities of listed regulated substances. The RMP regulations require owners or operators of covered facilities to implement a risk management program and to submit an RMP to EPA. Each standard follows distinct guidelines and protocols to prevent and alleviate the risks linked with hazardous chemicals: Applicability: PSM applies to facilities in various industries where highly hazardous chemicals are handled, stored, processed, or manufactured, such as chemical manufacturing, oil refining, and pharmaceuticals, among others. The regulation applies to any facility where the threshold quantities of listed HHCs are present or has flammable materials, those with a flashpoint below 1000F, above 10,000 lbs onsite and no other exemption applies. RMP applies to facilities that handle specific listed regulated substances above certain threshold quantities. Facilities covered by RMP must prepare a risk management plan, conduct a hazard assessment for potential releases and, in some cases, implement an emergency response program and a prevention program to prevent and mitigate accidental releases of these substances. Program Requirements: Both PSM and RMP have specific requirements for preventing or minimizing the consequences of catastrophic releases.  The requirements for PSM and RMP Prevention Program 3 include elements such as process safety information, process hazard analysis, operating procedures, training, mechanical integrity, management of change, and emergency planning and response. With regard to differences between the regulations, PSM includes a trade secrets element, while RMP does not.  And, unlike PSM, RMP requires the submittal of a Risk Management Plan to EPA and a hazard assessment of the impact of potential releases.  Also, depending on the potential risk posed by the regulated substances onsite, RMP has different program levels (Program 1, 2 and 3) that determine the extent of emergency response and prevention activities required. A site’s RMP program level is determined by the potential for impacts to public receptors from a worst case release, site release history, facility North American Industry Classification System (NAICS) code  and whether the facility is also regulated under the PSM standard. The program levels specify requirements for release case analysis, five year accident history compilation, and type of prevention plan and emergency response program to be implemented, if any. Reporting Requirements: Facilities covered by PSM are required to internally compile and maintain comprehensive process safety information, including data on the chemicals, technology, equipment, and procedures used in the process.  PSM has no external reporting requirements to OSHA but internal requirements for documentation of compliance include process hazard analyses (PHAs) reports, written operating procedures, operator training records, mechanical integrity testing and inspection records, and incident investigation reports. While RMP internal documentation requirements for Program Level 3 prevention programs are almost identical to OSHA PSM requirements, RMP does have additional requirements based on program level determination. Program Levels 1, 2 and 3 must all submit a Risk Management Plan externally to EPA, conduct and document release analysis, prepare a five-year accident history and coordinate with local response agencies.  Program Levels 2 and 3 must also implement a management system, a prevention program and an emergency response program, if applicable. Both PSM and RMP mandates an evaluation every three years to ensure continued compliance. In conclusion, both programs share the overarching goal of safety; they have distinct elements, applicability criteria, and regulatory bodies. It is essential for organizations to navigate these requirements carefully to ensure compliance and, more importantly, to enhance safety for their workers and the surrounding community. PSM RMP Services

by Tom McGreevy, PE, PMP, CFSE, CAP Congratulations! You’ve been assigned a project to replace your plant’s control system. Perhaps, rather than being in a congratulatory mood, you’re thinking, “What did I do to deserve this?”. Both feelings are understandable – a control system replacement project can be, at the same time, a rewarding, hugely beneficial business and career opportunity and an extremely stressful, sometimes thankless, and even less than fully successful experience. This is the initial installment in a series on control system migrations starting with the most common first step in any such project: Building a financial justification. The first thing most people consider when contemplating a major investment, whether it be in one’s work life or at home, is “How much is it going to cost?”. Of equal importance should be “How much will it save us in the long run?”. A well-developed financial justification, also commonly referred to as a “business case”, will evaluate both the cost and the benefits over the expected useful lifetime of the system. How Much Will It Cost? Developing a cost estimate should be an iterative process, starting with a relatively high-level cost estimate in the earliest stage of project consideration. The initial investment must be estimated, and the annual cost of maintaining the system must be included, to develop a total life-cycle cost. Let’s consider the initial investment, the “capital outlay,” and the annual costs, the “maintenance costs,” for the life of the new system: Total Life-cycle Cost = Capital Outlay + Annual Maintenance Costs Capital Outlay The initial capital investment can, in the earliest stage of the project, be estimated in a number of ways prior to having a fully detailed project scope: Parametric: Estimate based on key parameters inherent to the system. For a control system this could be “per I/O point” or “per tag." Configuration costs could perhaps be estimated on a “per line of code” basis or “number of system graphics” basis. Analogous: Estimating the proposed project based on a similar past project, with adjustments made for known scope, size, and time since the past project was completed. Actual Costs: Similar to an analogous estimate, but applicable if a very similar, very recent project has been completed. Other cost estimating techniques, most commonly the Bottoms Up Engineering Estimate, are typically not practical in the early stage of a project, as the full scope and associated design deliverables are typically not yet developed. However, this method is commonly used for final capital expenditure approval and is typically shown as a +/-10% number. Annual Maintenance Costs Depending on your organization’s accounting methods, some of the costs normally classified as “maintenance costs” can be initially capitalized and included in the capital outlay estimate. However, from the point where the asset becomes utilized, annual maintenance and upkeep costs are typically expensed by the business. These costs must be estimated over the assumed lifetime of the asset. Your organization may have reasonably good historical records of such costs, and you may be able to get assistance from systems integrators or vendors for costs such as: Annual license updates Minor to major system upgrades Spare parts Operator and Maintenance Technician training Preventive maintenance Another key annual cost to be considered is the annual cost of system downtime: or the number of hours per year that the system is not available to support production. Given that it will be a new system, this should be a very small percentage of hours on an annual basis. However, to consider 100% availability is simply not realistic, so consider the Availability carefully. In a very large facility such as a refinery, even a 99.99% availability can have significant cost implications. Early-stage cost estimates should not be touted as having high levels of accuracy – typically +/- 50% at first look. A word of caution: Upper management may latch on to the first number as a “Not to Exceed” (NTE) – judicious communication that there is both a “+” and a “-“in front of the number is recommended. Your business may operate in such a way that the number should be advertised as an NTE, in which case, err on the conservative side. If your project is executed in a stage/gate manner, which is highly recommended, you’ll have ample opportunity to sharpen and optimize the cost estimate as the scope is refined. How Much Will We Save? Now that you have a cost estimate, you need to evaluate the other part of the $ equation: How much will the new system save us? The difficulty of developing this number can range from relatively easy to very difficult. Perhaps your existing system has suffered a failure that directly resulted in very real costs to your organization, and you know this number only too well. You are fortunate to have this cost available, as it is likely well-known to management, and they are chomping at the bit to avoid a repeat performance. If this is the case, strike while the iron is hot! Often, however, your system has had less significant failures or “near misses” that, through perhaps heroic efforts, your team was able to ride through to keep production up. In such cases, estimating the cost of a “what-if” scenario is necessary. Working with your operations & business departments can usually result in reasonable estimates of both direct and opportunity costs that can be developed into an overall cost avoidance number. Failures in a “Sold Out” production mode are often the difference between successful and unsuccessful financial justification. Annual maintenance and upkeep costs are hopefully available, and it is very common that, for older systems, these costs are known and have been increasing. Other annual upkeep costs are not so easy to estimate. You may have older employees who have operated and maintained the system for years and are close to retirement. It can be very challenging to pass this know-how and experience, much of which may be “institutional knowledge”, to new employees. Many factors, including legacy, proprietary protocols, poorly documented control system logic, and even “black box” components that are poorly understood or simply no longer available to purchase, have associated upkeep or loss costs. The team should make attempts to develop estimates of annualized costs for these other factors to capture the overall “How Much Can We Save” part of the equation. Similar to annualized upkeep costs for the new system, the “How Much Can We Save” number is typically spread over the assumed lifetime of the new asset, using an annualized assumed risk of realizing one or more assumed failures. Armed now with both “How Much Will It Cost?” and “How Much Can We Save?”, these numbers can be analyzed in a number of ways to arrive at a net financial justification. Common methods include: Return On Investment (ROI): How many years will it take to break even on the initial capital outlay? The smaller the number, the more attractive the investment. Operating Expense: What is the net impact on annual expenses to maintain the system? Net Present Value (NPV): An objective calculation of the net positive (or negative) value, today, of the project, looking at its entire lifespan. The higher the number, the more attractive the investment. Internal Rate of Return (IRR): An alternate view of the relative attractiveness of the investment, also looking at the entire lifespan. The higher, the better. Your organization may use one or more of these techniques. Many companies have minimum acceptable investment criteria for project approval. Some events and their associated costs can be very challenging, sensitive, and proprietary to estimate. Consider the cost to the business of a fatality that can be attributed to a system failure. Some organizations will avoid estimating such a cost altogether, and simply use a risk matrix methodology to justify a project. This is typically done by looking at “Where are we now?” on the risk matrix, compared to “Where does the new system get us?”. Typically, a new control system, or perhaps a new Safety Instrumented System, can result in an estimated risk reduction of two orders of magnitude. A risk matrix system can also be used for environmental or business reputation evaluations as an alternative method for justifying a new control system. Project Scope In order to develop your first business case, you need to have at least a preliminary project scope from which to form a cost basis. It is highly recommended that you formally document your Basis of Estimate in parallel with your financial justification and be prepared to defend it as it goes through the approval process. Building a financial justification for a control system migration or upgrade project is the first step in developing a solid, executable plan. This plan, if appropriately risk-based, will increase the likelihood of success, resulting in a positive project experience. Additionally, it can contribute to the creation of a valuable new asset that helps realize your organization’s business goals in a safe and reliable manner.

Engineers Week was established in 1951 as a way to promote a diverse and well-educated future engineering workforce by increasing understanding of and interest in engineering and technology careers. Each year, aeSolutions celebrates Engineers Week by hosting fun activities for our employees, and by sharing resources and stories that highlight how engineers – and engineering companies – make a difference in our world. This year we asked our employees a series of questions related to engineering and engineering companies as a career choice. We’ll be share some of their answers over the course of Engineers Week, which runs from February 18-23. These questions focus on why our employees chose engineering as a career, and the impact they believe that has had on their communities. Why did you choose engineering as a career path? Solving problems.  I am not a fan of puzzles. Someone else has determined the final outcome before you have started.  Solving a problem is gathering information and creating a solution that can be presented to a team or client for further refinement.  – Andy G. I was a single-parent and needed a career that would enable me to support my two daughters and myself. I had worked in retail, restaurant, and banking industries and I was bored working at a bank. I attended a course at a community college called, Women In Transition. This program used various tests and tools to research what career would be a good fit. I learned I had similar interests with engineers and military officers. Since military was not an option for me. It was a matter of which discipline to pursue.  I learned how to obtain scholarships, and quit my banking job to purse an engineering degree.  Once I took General Chemistry, I knew Chemical Engineering was the path for me. – Kelly J. My high school guidance counselor suggested engineering because I was taking three math electives at the time. At the time, I really did not know what engineers do. – Ken O. I did well in math and science in school and had two relatives in engineering who encouraged me to consider chemical engineering as a career.  One was a chemical engineer who was head of nuclear safety at Oak Ridge Laboratory and the other developed nuclear weapons integrity tests at Sandia Laboratory in New Mexico.  They always had interesting experiences to relate about their jobs, so I decided before I ever entered high school to follow them into engineering as a career. – Melissa L. I've always loved tackling the unique challenges that engineering can throw at you. – Joel R. How would you describe the impact that your choice to go into engineering as a career has had on your community? I have an amazing ability to fix stuff that most neighbors pay others to fix or throw it away.   I was extremely valuable to all three sons as a consultant for their science fairs.  My Den and Boy Scouts knew more about electricity, electronics and electromagnetism than most middle school science teachers.   I can tutor students in Calculus, Chemistry, Physics, etc.  – Tom M. Over a 35+ year career, I would like to think that many of the projects that I have worked on have provided a safer work environment for many and provided clients with the means to conserve capital. – Andy G. My children learned you can do anything if you never give up. I worked on campus as a tutor and professor assistant, including volunteering for campus activities.  We were engaged in the local community through the colleges I attended. I taught my girls civic engagement and obligations are part of who we are.  I became an Engineering Ambassador visiting high schools to encourage students to study engineering at Texas Tech University.  It would be fun to learn, what great things the students have accomplished that I encouraged to pursue engineering. – Kelly J. My engineering training helped me build problem scoping and solving skills. In my community such as at church and in different organizations that I belong to, I have a reputation for being a quick problem solver. – Ken O. I hope I've had a hand in keeping Chemical plants a little safer over the years, ensuring they are meeting all required regulations. I also hope I've encouraged other young woman to join math/science fields through career shows at the local high schools. – Carolyn B. I have tried to promote engineering in a small way by discussing my experiences with friends' children who were considering majoring in engineering and in participating in career days/science fairs at local schools.  Kids do not often have a lot of exposure to engineering as a career choice or understand exactly what engineers do. – Melissa L. I believe that through my efforts the many plants I have worked in have become safer places to work and safer for the communities around them. – Kelvin S. I have worked in several different industries and contributed to their manufacturing processes to ensure they stay running, such as power and mining, both of which are used in goods for services people use. – Mark S.

Engineers Week was established in 1951 as a way to promote a diverse and well-educated future engineering workforce by increasing understanding of and interest in engineering and technology careers. Each year, aeSolutions celebrates Engineers Week by hosting fun activities for our employees and by sharing resources and stories that highlight how engineers – and engineering companies – make a difference in our world. This year we asked our employees a series of questions related to engineering and engineering companies as a career choice. We’ll be sharing some of their answers over the course of Engineers Week, which runs from February 18-23. Today’s question focuses on advice our team members would give. What advice would you give to someone considering a career in the engineering fields? You'll never or rarely be unemployed. You probably won't get rich, but you can live a comfortable life and have fun work.  Also, if you cannot otherwise hunt or aren't trained in paramilitary operations, being a good engineer will ensure you are a valuable asset to any number of tribes or gangs when the inevitable Zombie Apocalypse happens.  I mean, even Negan would have really loved a guy who could make electricity from parts found in a junk yard. – Tom M. If a person is looking at a career in engineering or design, learn the basics, get a grasp on newer technology and be willing to learn from those with the experience. – Andy G. You can do it, just be tenacious with your learning.  This includes a strong component in communication skills, verbal and written.  Most engineers hate writing because they love the sciences and math.  If you can't sell your solution ideas or document how you got to the idea, then no one benefits. – Kelly J. As an engineer, early in my career, I believed that with the right technical solution all problems could be overcome, that the "wisdom" of a solution would win the day. Since then, I have learned that people must be met where they are. Invest the time to understand what is motivating them, what is important to them. Deliberately seek this information from them. Express a willingness to understand and to compromise. This takes time and patience but it's the only way that I have found to achieve sustainable change. – Ken O. You don't have to be the smartest one in the room. You just have to want it the most and never give up on your goals. Once you become an engineer, the jobs are extremely varied and you can find your passion. – Carolyn B. If you choose engineering as your career, your education will give you many job opportunities whether you end up working as an engineer or not.  A solid background in math and science can be used as a springboard for many types of positions i.e. teaching, medical technology, business etc. – Melissa L. If you are considering an engineering degree, be the best you can be to help others for now and in the future. What you design can have lasting impacts on many people. – Kelvin S. Look at all the possible fields in which you can apply an engineering degree. I was convinced I HAD to work in gas and petroleum with my degree, and I am glad I was able to avoid that. – Ethan W. Be prepared to be challenged and dedicated to your work. – Mark S. I'd advise them to study hard and be ready for difficult, yet interesting, challenges. – Joel R.

aeSolutions Panel Fabrication Shop Celebrates Safety Award Recognition Greenville, South Carolina, USA – May 20, 2016 – For the second year in a row, the South Carolina Chamber of Commerce has recognized aeSolutions with its Commendation of Excellence award. The award, presented by the Chamber’s Safety, Health and Security Committee, recognizes South Carolina Chamber members with a successful workplace safety record during 2015. The Chamber’s annual Safety Awards recognize companies and their employees who have had a commendable Lost Workday Case Rate during the calendar year. Recognized companies are committed to the health and safety of their employees. Both of aeSolutions’ South Carolina locations received awards. aeSolutions – Corporate occupies a 24,000 sq. ft. office space in Greenville, South Carolina. Their Merovan location’s 14,000 sq. ft. complete panel fabrication facility manufactures and ships large control panel systems to clients across the United States. “Safety is one of aeSolutions’ core values; it is at the root of our company’s culture,” stated Mike Davenport, aeSolutions’ Vice President of Operations. “From the services we provide to clients operating in some of the most dangerous environments in the world, to the care we take with our internal work policies and practices, safety is what drives us. We are motivated by ensuring every one of our customers and employees gets home safely every day; it’s who we are.” In 2015, both of these locations reported zero lost-time accidents, as did the company’s Alaska and Houston offices. This is the fourth consecutive year that aeSolutions has posted zero lost-time accidents company-wide. “A safe workplace allows employees to grow and succeed, and we are proud to announce this year’s Safety Award winners who have taken that to heart,” states Ted Pitts, President and CEO, SC Chamber of Commerce. “We are pleased to honor those companies who have made safety a top priority over the last year and to recognize them among peers at our annual Safety Awards event.” About aeSolutions In business since 1998, aeSolutions is a complete supplier of performance-based process safety engineering and automation solutions. To fulfill their mission of continuously improving the safety performance of the process industry, they utilize proven processes to help ensure consistent project execution and help customers optimize production, quality, and safety. aeSolutions is committed to providing engineering services that enable our clients to sustainably own, operate, and maintain their process facilities. ###

By Warren Johnson, Senior Project Manager, FGS Product Manager Regulatory compliance is a moving target. Codes and standards are under ongoing revision and the business landscape is constantly evolving. Fire and gas systems are protecting an organization’s most valuable investments and assets, yet they sit silently idle in the background often overlooked and untested. The maze of local, state, and federal codes and standards just add to the confusion and complications. The Challenges Many engineers working in the industrial manufacturing sector do not have first-hand working knowledge of the codes and standards that govern these critical life safety systems. Many of those that do are beginning to retire, leaving newer, less experienced staff in their place. There are 37 different pieces of equipment requiring OSHA’s Nationally Recognized Testing Laboratory approval. It’s understandable that these less experienced employees do not have the background to navigate all the specific code requirements governing the equipment for which they are responsible. These emerging engineers will need guidance. Even teams with extensive compliance experience know that these codes change and evolve, so they cannot rely solely on how things have been done in the past. The Stakes Creating a safer work environment protects both a company's personnel and its assets. Failing to do so can result in personnel injury, damage to the environment, and irreparable harm to a company's reputation. Poor code compliance may jeopardize insurance coverage or cause increased premiums. Code deficiencies found late in a capital project may lead to costly startup delays until compliance is achieved. The Most Common Codes Everyone Should Know ⮚ International Fire Code – Regulates the means of protecting lives and material property from fire or explosion hazards when modes of prevention fail. ⮚ International Building Code – Covers all codes regarding buildings except for residential family homes. ⮚ Life safety 101 – This established set of standards is intended to protect the occupants of a facility at each stage of the building’s life cycle—from construction to its intended use and eventual demolition— minimizing the effects of fires and other related hazards. ⮚ NFPA 72 – The National Fire Alarm and Signaling Code provides updated safety protocols to meet the ever-changing demands for improved fire detection, signaling, and emergency response communications. This code also regulates requirements for mass notification systems used for a wide range of emergencies from catastrophic weather, terror threats, biological dangers, chemical incidents, and even nuclear disasters. ⮚ OSHA 1910.164 – Standardizes regulations for fire alarm detection systems and OSHA 1910.165, which focuses on regulating employee alarm systems specifically. Capital projects need to incorporate the requirements of these standards into their design since they are the most prevalent in constructing a facility. Compliance is far less likely without a deep understanding of these standards and where each applies. Most compliance errors are made due to: The lack of awareness of relevant regulatory codes. A deficiency in understanding requirements well enough to apply them properly. Organizations that wish to avoid the cost and confusion over non-compliance need to do the research and audit their practices. The caveat with self-auditing code compliance is that it can be like looking for a needle in a haystack without knowing what a needle looks like. Companies that do not know what codes to look for or which apply to their facilities may benefit from engaging a firm that specializes in regulatory code compliance. Learn More about aeSolutions' Fire & Gas Services