PLEASE NOTE the LOI in which OSHA adopted EPA’s 1% rule was thrown out by the courts so I am NOT 100% sure OSHA can use the 1% rule from EPA in their evaluations of what is a covered process/HHC. Last week OSHA changed their position in how they will handle “mixtures” of those chemicals listed in…...
Pressure decay testing, monitoring a gauge for a pressure drop over a specified period, is unacceptable as a standalone leak test under ASME B31.3 because the code explicitly mandates a 100% visual examination of all joints and connections while the system is under test pressure. While a pressure decay test can indicate that a system…...
With OSHA’s change last week in how PSM applies to “mixtures” of HHCs I have received a number of questions about “partial pressure” and what impact it can have on whether my process is covered or not? EPA has been using “partial pressure” of 10 mm Hg for their mixture applicability rule since 1999, but…...
I shot this video just before my safety training session at a safety convention this summer. When I asked for it to be fixed, the venue manager and workers were confused because the projector had power. When I tried to explain the issue they all of a sudden had trouble with the english language. If…...
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Yes, OSHA has rules for the use of flammable liquids in areas that are not designed as a Hazardous Location. OSHA covers Hazardous Locations in 1910.307, but those areas that do not rise to the level of being a Hazardous Location fall under 1910.334(d) which states:… Membership Required You must be a member to access...
MEMORANDUM FOR: REGIONAL ADMINISTRATORS AND STATE PLAN DESIGNEES THROUGH: DOROTHY DOUGHERTYDeputy Assistant Secretary FROM: THOMAS GALASSI DirectorDirectorate of Enforcement Programs SUBJECT: Process Safety Management of Highly Hazardous Chemicalsand Covered Concentrations of Listed Appendix A Chemicals This memorandum revises OSHA’s enforcement policy on the concentration of a chemical that must be present in a process for…...
MEMORANDUM FOR: REGIONAL ADMINISTRATORS AND STATE PLAN DESIGNEES THROUGH: DOROTHY DOUGHERTYDeputy Assistant Secretary FROM: THOMAS GALASSI DirectorDirectorate of Enforcement Programs SUBJECT: RAGAGEP in Process Safety Management Enforcement This memorandum provides guidance on the enforcement of the Process Safety Management (PSM) Standard’s recognized and generally accepted good engineering practices (RAGAGEP) requirements, including how to interpret “shall” …...
Today the US Chemical Safety Board released a DRAFT report on a 2009 Explosion and Fire at a petroleum terminal facility. So far, the CSB has identified “Inadequate Management of Gasoline Storage Tank Overfill Hazard” as the root cause of this accident. I can still remember the 2005 Buncefield incident that very closely mirrors this…...
CLICK HERE (doc) for one of the Contractor Work Permit written program that I used during my time as a Safety Manager in the chemical industry. CLICK HERE (pdf) for the Work Permit… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
June 2015 marks the one-year anniversary of EO 13650 – Actions to Improve Chemical Facility Safety and Security – A Shared Commitment: Report for the President. The EO Working Group has released a fact sheet on the accomplishments to date on improving chemical facility safety and security since the publishing of the Report to the…...
This week I am teaming up with my friend and safety colleague Jonathan Zimmerman at the 2015 ASSE Conference. I have uploaded our presentation, as well as the PSM Inspection Data that was so generously provided by some other friends who I can not mention publicly (but you know who you are and THANKS a…...
