A few years ago I wrote a piece about identifying ALL equipment, especially valves, with a unique identifier. The purpose of that posting was brought about by a lot of facilities challenging our PHA, II, Audit findings/recommendations that all equipment be identified with a unique identifier in the field, on P&ID’s, in SOPs, LOTO procedures, […]
As a follow-up to my 2014 post, Are you maintaining your LEVEL A suits “by the book”? , where I covered the care/testing requirements for my brand of LEVEL A suits, I wanted to make sure the word is out… ALL LEVEL A suits built to ASTM F1461-17 REQUIRE some specific testing and inspection in
At 12:30 am on May 30th, 2020, failure of a 6” pressure piping elbow located on top of a storage tank resulted in black liquor being sprayed onto adjacent buildings, equipment, and ground within an approximately 50m (165′) area. The line from the liquor transfer pump into the top of the tank failed and 74%
To reduce the risk of more than 300 chemicals of interest (COI) being weaponized, the Cybersecurity and Infrastructure Security Agency’s (CISA) Chemical Facility Anti-Terrorism Standards (CFATS) program identifies and regulates high-risk chemical facilities to ensure appropriate security measures are in place. Under CFATS, a chemical facility is “any establishment that possesses or plans to possess
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…
