Yes, as I posted a couple of weeks ago, the RMP Amendments are now in effect (at least those with compliances dates that have passed – some have dates further out). One such requirement that seems to be causing a stir is “3rd Party Audits” for Program 2 and 3 Level RMP processes (e.g. 68.59 […]
UPDATE: Earlier this year I posted a news account of an NH3 release in Cincinnati because of statements from a VP of the company stating an “explosion had occured”. I have since learned that yes it was an “explosion”, but not one involving fire as so many think of when they hear that word. From
Inspection of buried process piping is different from above ground process piping because significant external deterioration can be caused by corrosive soil conditions and the inspection is much more difficult due to the inaccessibility of the piping. However, as difficult as it may be, buried piping MUST be inspected to determine its external surface condition.
I was recently reminded of how so many in process safety struggle to see their process(s) thru different lenses based on the piping’s life cycles. Using ASME B31.3 and 31.5, we see that these codes (e.g. RAGAGEPs) are design and build piping standards. Looking at API 570 series we see these are codes (RAGAGEPs) for
In OSHA’s 2018 fiscal year it conducted 28 inspections at Refrigerated Warehouses and Cold Storage facilities. This resulted in 84 citations being issued, totaling $426,241. The Top 10 Standards OSHA found issues with were:
This week EPA updated the RMP Rule, which includes all of the amendments that had been delayed. One such amendment was to §68.96 Emergency response exercises where EPA now requires facilities with Program 2 and 3 covered process to conduct some “official” actions in regards to “table-top” and “field exercises”. In this article I will break down
The Environmental Protection Agency (EPA) announced today (12/4/2018) that the amendments to the Risk Management Program under the Clean Air Act put forward in a final rule published in the Federal Register on January 13, 2017 are now in effect. The rule amending 40 CFR part 68, published at 82 FR 4594 (January 13, 2017)
Inherently safer practices are an approach to the design of safer chemical processes with clear potential benefits related to safety, health, and the environment. Following are strategies for achieving an inherently safer process:
I have discussed this many many times with clients over the years, as most have difficulty seeing the logical transition from each phase to the higher level of response. So in this article, I will attempt to show the transition as to when we leave PSM/RMP operating procedures to our EAP and if necessary how
This is a recording of a live session that took place on October 30, 2018. The session was intended for refrigeration contractors & mechanics. The following was covered: Key findings of the Fernie Investigation Recommendations from the Investigation that pertain to owners/operators of ammonia refrigeration plants Open question & answer period
This is a recording of a live session that took place on October 30, 2018. The session was intended for refrigeration contractors & mechanics. The following was covered: Key findings of the Fernie Investigation Recommendations from the Investigation that pertain to owners/operators of ammonia refrigeration plants Open question & answer period
OSHA’s and EPA’s process safety standards require the host facility to “explain to contract employers the applicable provisions of the emergency action plan” (1910.119(h)(2)(iii), which is a REQUIRED PLAN for all facilities with a PSM/RMP covered process. But what does OSHA/EPA mean when they use the phrase “applicable provisions of the emergency action plan“? We
