Emergency Escape Breathing Apparatus (EEBA) are making come back – at least I am finding more and more facilities that never had them now implementing them for many reasons. Some companies now believe they are required because of PSM/RMP, some 3rd party PHA facilitators must be getting kick-backs as a lot are recommending them in […]
The client has approved this posting as they want to make sure others can learn from their incident. PLEASE discuss this incident with your teams if your LOTO practice(s) resemble theirs – what they did was VERY COMMON and I teach this method in all my LOTO courses at process plants. I have revised my
If there is one common finding in our PSM/RMP audits it is this single requirement for employees who remain to operate critical plant operations before they evacuate. And when we attempt to explain what is actually necessary to just meet 1910.38(c)(3) we are oftentimes met with downright hostility. It is rare these days that anyone
Section 304(a) of EPCRA and the regulations found at 40 C.F.R. Part 355, Subpart C, require the owner or operator of a facility at which a hazardous chemical is produced, used or stored, to immediately provide notice to the State Emergency Response Commission (SERC) and the Local Emergency Planning Committee (LEPC) as described in Section
The risk management program regulations require the owner or operator of a covered stationary source to develop and implement an emergency response program as described in 40 CFR §68.95, which must include an emergency response plan, emergency response equipment procedures, employee training, and procedures to ensure the program is up-to-date. Do all facilities subject to
Formaldehyde is not specifically listed with a concentration cutoff, but is listed with the qualifier “solution”. Can the partial pressure exemption be applied to formaldehyde solutions?
The Risk Management Program emergency response coordination activities require the owner and operator of a stationary source to provide to the local emergency planning and response organizations: the stationary source’s emergency response plan if one exists; emergency action plan; updated emergency contact information; and any other information that local emergency planning and response organizations identify
On August 18, 2018, the EPA issued to Respondent a Notice of Potential Violation (“NOPV”), providing notice that the EPA found that Respondent had potentially committed the alleged violations described in Section V of this Agreement and providing Respondent an opportunity to confer with the EPA. On February 14, 2019, representatives of Respondent and the
The Pipeline and Hazardous Materials Safety Administration (PHMSA) has developed a free, mobile web app of its Emergency Response Guidebook 2020 (ERG). The new safety tool provides the nation’s emergency responders with fast, easily accessible information to help them manage hazardous material incidents. This software is available from the Apple iTunes store for iPhone, and
A wise plant manager told me this in my first year in the petrochem industry. I am paraphrasing When it comes to our primary containment systems (he was speaking to piping in this discussion) – if it is not done darn near perfect, all we have to do is wait a while and bad things
OSHA does not mandate that employers establish fire brigades; however, if they do so, they must comply with the provisions of the Fire Brigades Standard. The provisions of the standard, including the paperwork requirements, apply to fire brigades, industrial fire departments, and private or contract fire departments, but not to airport crash rescue units or
As I stated last week and posted my updated RMP Audit Checklist ER questions, the RMP ER coordination activities should be at least in your “planning/discussion” phase with your off-site responders/resources. Even though 68.10(b) states that compliance with these activities must be completed by March 14, 2018 and the fact that the amendments did not
