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One state and two territories no longer implement the program, and the Regional office has taken over implementation for those three (3) areas. One (1) county in KY and three (3) counties in NC have been delegated enforcement authority. FL, ND, and MO have a partial delegation for either LPG or NH3.
The current list of delegated states is:
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I grew up in the process industries doing PSM/RMP; however, most of the air receivers at my plants were NOT associated with the PSM/RMP-covered process(es). And yet they were all in our MI program for routine inspections and testing of their PSVs. In fact, every pressure vessel in service on the plant site and its associated PSVs were managed the same way we managed our PSM/RMP pressure vessels....
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OSHA has made significant changes to Chapter 4, The VPP Safety and Health Management System. Chapter 4 now requires VPP participants’ SHMS to consist of the seven (7) core elements described in OSHA publication 3885, Recommended Practices for Safety and Health Programs, October 2016, and in OSHA publication 3886, Recommended Practices for Safety and Health Programs in Construction, December 2016. These...
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NOTE: If you’re in an INDUSTRIAL facility, especially one with a PSM/RMP-covered process, B31.9 is NOT your piping RAGAGEP!
IFC 5703.6.3 dictates that piping for flammable and combustible liquids must be hydrostatically tested to 150% of the maximum anticipated pressure (or pneumatically tested to 110%). However, it offers a carve-out:
“Unless tested in accordance with the applicable...
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I get some interesting questions and see some very strange things in my work around the country, but this one seems to have grown legs in the world of “cost-cutting” in safety. “Let’s have our maintenance people do the ‘annual maintenance’ on our fire extinguishers”… um NO WAY! And this is just not a “Haywood Safety Thing”… it’s...
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I will be fully upfront for those who wish to challenge me on this topic. YES, ASME B31.3 and 31.5 explicitly state that certain records that are required by the standard do NOT have to be “retained”. However, most people who challenge me on this topic fail to see that ittybitty two-letter word “if” in the code and in the world of Process Safety, these records most certainly...
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Structural collapse caused the release of around 2,400kg of highly flammable liquid petroleum gas.HSE investigation found that long-standing corrosion of the steel tower was not dealt with.Workers exposed to the risk of serious injury and burns in a major incident.
The refinery has been fined £1 million after a major gas leak following an investigation and subsequent prosecution by the Health...
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The Chain of Failure
The catastrophe centered on the unloading area for liquefied petroleum gas (LPG) tanker trucks and unfolded over a matter of minutes.
Botched Connection: Around 1:00 a.m., a driver attempted to connect an omnidirectional loading arm to the tanker’s discharge outlet. The connection procedure was complex, and the driver failed to secure it properly.
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OSHA uses the General Duty Clause (GDC), Section 5(a)(1) of the OSH Act as a “gap filler” to cite employers for recognized chemical hazards when a specific standard (like the Process Safety Management standard, 29 CFR 1910.119) does not technically apply. There are some critical legal limitations on GDC Enforcement:
OSHA’s ability to invoke 5(a)(1) in process safety situations faces...
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Not having an ammonia detection system, which had been cited the previous year, also as a GDC; however, it seems the business was sold, and the new owner was cited for not addressing the detection system.
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As I said in my previous posts on GDC PSM citations, this is new territory for me and OSHA enforcement. I was always taught (and by some very sr. OSHA personnel) that OSHA can not use the GDC to enforce hazards for which OSHA already has a standard for. It was OSHA’s “carrot and stick” approach to PSM, stating that if a facility gets below the HHC’s PSM TQ, then it would not...
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Apparently, they can and have. Here are some GDC citations for an NH3 refrigeration process. These were part of a large release inspection that included some HAZWOPER and HAZCOM citations. My only guess is that these GDC citations are tied directly to the NH3 release, but I have not yet seen the field notes, so I am not sure. Each GDC citation below had a $16,550 tacked onto it, but was negotiated...
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