Fertilizer Canada created the Anhydrous Ammonia Code of Practice (Ammonia Code) to provide uniform safety and security practices for the handling and storage of anhydrous ammonia at ag-retail facilities in Canada. The Ammonia Code outlines best practices applicable to the transportation, distribution, storage, and handling of anhydrous ammonia associated with these facilities. The Ammonia Code […]
NOTE: I normally do not post such small cases; however, this one involved the use of The Chlorine Institute pamphlets as the referenced RAGAGEP and because it is so rare we see Cl2 PSM/RMP citations I wanted to add it to the database. Based on a compliance monitoring inspection conducted at the Respondent’s facility on
Respondent is the owner and/or operator of the Facility, which operates an aircraft parts and auxiliary equipment manufacturing plant. Respondent has registered an RMPlan with the EPA for its Facility and has developed an RMProgram accidental release prevention program for the Facility. At its Facility:
Respondent is the owner and/or operator of the facility, which produces fully cooked and ready-to-eat sauces and refrigerated entrees. On December 26, 2018, the EPA issued to Respondent a Notice of Potential Violation (“NOPV”), providing notice that the EPA found that Respondent potentially committed the alleged violations described in Section V of this Agreement and
This is another case where OSHA and EPA compliance may be the least of our concerns, as this is REAL LIFE process safety – NOT compliance work! Yes, we have to comply with our repair RAGAGEP; but I was referring to whether a facility does a MOC or not. Let’s examine this type of work
Although I agree with most of EPA’s FAQs regarding their RMP standard, this one is just sad! The question was asked… Are Mechanical Controls Considered Administrative Controls? EPA and I could not be further apart on this topic, as EPA actually stated they would NOT accept an engineered hi-level alarm/interlock and would only accept a
EPA will, according to the regulations at 40 CFR §68.220(b), select stationary sources for audits based on any of the following criteria:
The prevention program requirements under 40 CFR Part 68, Subparts C and D, include “hazard reviews” and “process hazard analyses”. Is a “hazard review” synonymous with a “process hazard analysis” (PHA)? No, and here is the difference…
If an incident caused by theft or other criminal activity at a covered facility resulted in or could reasonably have resulted in a catastrophic release of a regulated substance, then the owner or operator of the covered facility must perform an incident investigation. If it would be unreasonable, based on the owner/operator’s knowledge of the
One of the top questions we get and it goes to HAZARDOUS MATERIALS MANAGEMENT! We have an EHS/HHC on site and today we are under the PSM and RMP TQ’s – KEEPING in mind that the standards have different TQ’s for many of the EHS/HHC’s. But if we do not manage these inventories AND cap
I have had seen dozens of facilities covering (albeit very poorly) a process that is NOT a PSM/RMP covered process because some consultant told them it was. The consultant(s) would point to an old statement by EPA that the Threshold Quantity (TQ) determination was based on the process’s ability to hold an amount exceeding the
EPA attempts to define and quantify how far apart separate vessels have to be to be considered different processes. There is no hard-and-fast rule for how great this distance should be before you can consider the vessels as part of one process.
