A Dairy in Puerto Rico has agreed to pay a penalty and make significant upgrades to settle RMP violations. The case stems from violations at two dairies located in Puerto Rico, including two major releases of anhydrous ammonia from one of the facilities. The Clean Air Act violations stem from the company’s failure of its…...
Two Washington state fruit companies failed to meet risk management plan requirements under the federal Clean Air Act, according to separate settlements with the U.S. EPA. As part of the settlements, the two companies will pay fines and submit missing reports to manage ammonia use. Both companies use more than 10,000 pounds of anhydrous ammonia…...
The potential impact of the use of compressed air for the removal of residual metalworking fluids on health was investigated using a test chamber approach followed by a workplace study. The former had the advantage in that the background levels of particles could be reduced significantly. The greatest risk was found to be dermal exposure…...
Since 2003, the International Fire Code has offered an “alternative” to complying with all the special hazard chapters of the “code”; it’s called the Performance-Based Design Alternative (PBDA). This alternative was intended to provide some relief to facilities that are already doing PSM/RMP style activities for their hazardous material(s) and to provide an IMPROVED alternative to…...
The management system required under Subpart A of 40 CFR Part 68 is essentially a system defined by facility managers for integrating the implementation of the risk management program elements and assigning responsibility for that implementation (58 FR 54196; October 20, 1993). The extent of the management system will depend on the size and complexity of…...
Field-expedient protection includes steps taken to provide immediate protection of personnel/materiel and to enhance protection of mission-essential facilities in the event of an incident. These procedures and planning factors are often included in emergency-action discussions of “protection in place” when it is required to sustain critical operations through an event or key infrastructure facilities that…...
The International Fire Code has another version of OSHA’s and EPA’s General Duty Clause. It is 5001.3 Performance-based design alternative. The code contains 18 elements that very closely mirror OSHA’s PSM and EPA’s RMP requirements, but the BIG DIFFERENCE is that the code makes no mention of quantities/thresholds! The rule applies to all hazardous materials,…...
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Often times we get so involved with meeting OSHA and EPA regulations that it is easy to loose site of the State Fire and Hazardous Material codes. In some states these codes can be even more stringent that OSHA and EPA process safety requirements! PLEASE keep in mind, each state will have their OWN SET…...
EPA issued a Process Safety Alert in 2007 in response to several investigations by the National Transportation Safety Board’s (NTSB) which involved the failure of excess flow valves (EFV). While EFVs are in extensive service and have prevented numerous pipe or hose breaks from becoming much more serious incidents, experience has shown that in some cases the…...
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A preliminary total of 4,609 fatal work injuries were recorded in the United States in 2011, down from a final count of 4,690 fatal work injuries in 2010, according to results from the Census of Fatal Occupational Injuries (CFOI) program conducted by the U.S. Bureau of Labor Statistics. The rate of fatal work injury for U.S. workers in…...
