Chemical Process Safety (PSM/RMP)

Congress meddling in PSM and OSHA Outreach Courses again

The Committee recommends $552,787,000 for the Occupational Safety and Health Administration [OSHA], which is responsible for enforcing the Occupational Safety and Health Act of 1970 in the Nation’s workplaces. The Committee continues bill language to allow OSHA to retain course tuition and fees for training institute courses used for occupational safety and health training and education…...

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CAL-OSHA shares details on NH3 HOT Gas/Oil Draining Valve Error Fatality

Readers of my Incident Alerts may remember this NH3 fatality from September 2012… AMMONIA FATALITY Winery worker dies after ammonia exposure (a worker at a winery has died after being exposed to ammonia – one of the workers accidentally opened a wrong valve and released ammonia into a confined area – the man was one of six workers exposed…...

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HI-OSHA gives Federal OSHA PSM Inspection duties

Many working professionals may not be aware that some states and territories have their own OSHA and others are covered by Federal OSHA.  In fact, twenty-six states, Puerto Rico, and the Virgin Islands have OSHA-approved State Plans. Twenty-two State Plans (21 states and one U.S. territory) cover both private and state and local government workplaces. The…...

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How did you “Class” your PSM/RMP covered process piping?

For those living the dream of being a process safety professional know that one of the fundamental decisions we eventually have to make is how will we “class” our PSM/RMP covered process piping.  For almost all of us, the best Piping Inspection RAGAGEP will be API 570, Piping Inspection Code and this RAGAGEP has a…...

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Did you ever think about the information collection requirements in the PSM Standard?

The major information collection requirements of the PSM Standard include:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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OR-OSHA announce PSM Inspection Selection Protocol (VPP Sites exempted)

Oregon OSHA has published their PSM NEP which focuses on processes with Ammonia, Chlorine, and Formaldehyde.  The NEP also EXEMPTS VPP sites from any inspections under their Emphasis Program.  To make the most effective use of its limited resources, OR-OSHA will use annual data gathered by the Oregon Office of State Fire Marshal (OSFM) Hazardous…...

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NH3 Fatality – Process Opening/Line Break Gone Bad!

A factory refrigeration technician who lost his lungs to an anhydrous ammonia leak has no case against his employer, a poultry plant in N.C.  The incident in June 2009 killed one refrigeration technician and injured another refrigeration technician and their supervisor. The injured refrigeration technician was in a coma for four to five months and had to have…...

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OSHA PSM Letter – Agricultural Retailers Association, et al. v. United States Department of Labor

VIA ELECTRONIC FILING May 5, 2016 Mark J. Langer, Clerk The United States Court of Appeals District of Columbia Circuit 333 Constitution Ave., NW Washington, DC 20001 Re. 28(j) Letter – Agricultural Retailers Association, et al. v. United States Department of Labor, et al., Nos. 15-1326 and 15-1340 Dear Mr. Langer: Respondents write to advise the…...

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OSHA’s behind the scenes political battle with PSM enforcement

Dear Member of Congress, I am writing to respond to concerns expressed regarding the Occupational Safety and Health Administration’s (OSHA) July 2015 retail exemption interpretation and to update you on regulatory action OSHA is taking in this matter.   … Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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OSHA issue Enforcement Policy Memo to Regional Administrators on “RAGAGEP in Process Safety Management Enforcement”

May 11, 2016 MEMORANDUM FOR: REGIONAL ADMINISTRATORS THROUGH: DOROTHY DOUGHERTY, Deputy Assistant Secretary FROM: THOMAS M. GALASSI, Director Directorate of Enforcement Programs SUBJECT: RAGAGEP in Process Safety Management Enforcement   NOTE:  much of the emphasis has been added by me This enforcement policy addresses the Process Safety Management (PSM) Standard’s recognized and generally accepted good engineering practices (RAGAGEP) requirements. Enforcement activity,…...

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OSHA Clarifies the Flammable Atmospheric Storage Tank PSM Exemption and why they seek to change it

The existing PSM standard applies in part to processes involving a flammable liquid or gas on site in one location in a quantity of 10,000 pounds or more. However, the existing PSM standard contains an exemption for “[f]lammable liquids stored in atmospheric tanks or transferred which are kept below their normal boiling point without benefit…...

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Process Safety Management SER Background Document (May 2016)

As an initial step, and prior to publication of any proposed changes to existing rules or enforcement policies, OSHA is convening a Small Business Advocacy Review Panel (“SBAR Panel”) in accordance with the Regulatory Flexibility Act, or RFA (Sections 601 through 612 of Title 5 of the United States Code). This Panel consists of members from OSHA, the…...

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