A couple of weeks ago, I wrote about how the Process Safety Information (PSI) “Safe Upper and Lower Limits” will differ from those “Safe Upper and Lower Operating Limits” found in our Operating Procedures. The article needed to be written as it received over 10,000 hits, and the e-mails continued with positive comments and more…...
Worked Example of Process Safety Information – “Consequences of Deviation” Read More »
PSM Retail Exemption Interim Enforcement Policy Employer(s) with employee(s) exposed to PSM-covered processes formerly exempted under OSHA’s 1992 interpretation of “retail facility” now must comply with the requirements of 29 CFR 1910.119 if the facility, or portion of the facility processing the highly hazardous chemical, does not fall into the North American Industrial Classification System…...
OSHA extends the compliance deadline for the REVISED PSM “Retail” Exemption (10/20/2015) Read More »
There’s a reason why both OSHA and EPA have requirements to CONTROL the entry of contractors into our covered process(s), their presence, and their exit from the process. It is so IMPORTANT, we find two (2) places in the standards that require this kind of CONTROL over contractors who wish to work ON, IN, or…...
Think you have control of your contractors? We may need to think again… Read More »
One of the most popular PSM requests I get is for an example of a “change to facilities that affect a covered process”. In this article, I hope to provide an actual example and how a “change to facilities” can affect an ammonia refrigeration facility. OSHA’s PSM standard states the following about managing changes… (l)…...
Material and Energy Balance and “change to facilities that affect a covered process” Read More »
CLICK HERE for the pdf. Many thanks to the CALOSHA Pressure Vessel Unit for sharing…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
ASME CODE and NBIC CHANGES 2015 EDITION Read More »
The recent change in OSHA’s PSM definition of a “retail facility” is having a large ripple effect all the way across EPA’s RMP rule. As I wrote about in “How does OSHA’s revised PSM “retail exemption” policy impact my RMP?” this change, thought by many as minor – thus the six-month compliance window for these…...
What it looks like to go from a Level 2 RMP to a Level 3 RMP Read More »
Comparing RMP Level 2 to Level 3 Programs RMP Program Level 2 RMP Program Level 3 §68.48 Safety information (a) The owner or operator shall compile and maintain the following up-to-date safety information related to the regulated substances, processes, and equipment: (1) Material Safety Data Sheets that meet the requirements of 29 CFR 1910.1200(g); (2) Maximum…...
Comparing EPA’s RMP Level 2 to Level 3 Programs Read More »
As we are now 20+ years into the PSM standard (16 years for RMP) I think it may be time to revisit the reason for these standards and what OSHA and EPA are trying to drive us to achieve and how our HHC/EHS inventory management plays a HUGE role in this effort. This MII requirement…...
What is the real reason for Maximum Intended Inventory? Read More »
Have you ever wondered why PSM and RMP require an employer to establish safe upper and lower limits for such items as temperatures, pressures, flows, or compositions in their Process Safety Information and evaluate the consequences of deviating from these limits, including those affecting the safety and health of employees? And then, in the Operating…...
Difference in PSI Safe Upper/Lower [DESIGN] Limits and SOPs Operating Limits Read More »
Current Policy PHMSA supports a practice of no gaps/no overlaps. PHMSA has not changed its policy or inspection approach toward processing facilities. PHMSA has no interest in regulating processing units. OSHA regulates gas processing units. PHMSA and OSHA are in agreement on jurisdictional lines. Neither PHMSA or OSHA are limited by fence lines CLICK HERE…...
Processing Facilities and PHMSA Jurisdiction (w/OSHA) Read More »
Questions and Answers from PSM Webinar Sept. 29, 2015. Answers provided by Jeff Wanko, PE, CSP, and Safety Engineer in OSHA’s Directorate of Enforcement, Office of Chemical Process Safety in Washington, D.C. Q. Do you have to test the safety equipment annually? A. Under paragraph (j), mechanical integrity, OSHA requires that employers inspect and test process equipment…...
There are so many learnings in this incident that every single business should analyze these against their current safety systems. Many of the issues that the Chemical Safety Board (CSB) investigation investigation identified are present in many other processing units handling Highly Hazardous Chemicals and Extremely Hazardous Substances. This is a breakdown of the items…...
Learnings from a catastrophic release of 24,000 pounds of methyl mercaptan Read More »
