While doing some a BLEVE risk assessment I came across this 2007 research paper that I thought was an incredible read. If you are one who works with BLEVE risk this is a MUST READ; if you’re someone who finds BLEVEs interesting and wants to learn the inner workings of a BLEVE, this paper breaks…...
Cal/OSHA today issued 19 citations to a refinery for workplace safety and health violations following an investigation into the February explosion at the company’s Torrance refinery that injured four workers. The proposed penalties total $566,600. Eighteen of the citations were classified as serious due to a realistic possibility of worker death or serious injury. Six…...
Cal-OSHA PSM citations @ refinery (Flammables & $566K) Read More »
I have been seeing a lot of RMP citations for failure to UPDATE the facility’s RMP every five (5) years. By far the number one issue this year based on the ESAs I have been trending. But one question comes to mind… RMP differs in PSM in a couple of ways, one way being that…...
EPA RMP citations for “failure to update RMP every five years and §68.15 Management Read More »
In the past couple of months OSHA has been rescinding LOIs and issuing new LOIs on PSM Retail Exemption and the 1% rule and at the top of these LOIs (posted online) is a “blanket statement” from OSHA that I find sort of humorous and sad at the same time… “OSHA requirements are set by…...
Process Safety irony of the week Read More »
In Part 1 of this series I established how this material is a Category 1 Flammable Gas based on both the manufacturer’s SDS and OSHA’s Hazardous Communications Standard Appendix B. In this article I wish to address how an HFO-1234yf storage tank, which is an ASME pressure vessel, should be labeled, versus how some have…...
Refrigerant HFO-1234yf is a Flammable “4” in the NFPA 704 Diamond (Part 2) Read More »
All year I have received dozens of phone calls and e-mails from friends and colleagues in the automotive industry regarding this new refrigerant for A/C units inside 2016 model vehicles. Over the next couple of months, I will be posting a series of articles about this new refrigerant and the impact it is having on…...
Refrigerant HFO-1234yf is a PSM Highly Hazardous Chemical (Part 1) Read More »
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Agricultural Retailers Association’s Letter to OSHA regarding the “retail exemption” Read More »
Everyone once in a while we come across purged and pressurized enclosures during our PSM/RMP audits involving processes that contain/process flammable liquids or gases. These purged and pressurized enclosures are used in lieu of using enclosures that are either intrinsically safe or explosion proof. But this method of protecting the process from ignition sources is…...
Using Purged and Pressurized Enclosures for Electrical Equipment (Hazardous Locations) Read More »
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 definition of retail trade (NAICS 44…...
OSHA’s PSM Retail Exemption Interim Enforcement Policy Read More »
Today, OSHA issued their revised policy on their “retail exemption” and this change in OSHA enforcement will actually impact thousands of businesses who have submitted a Risk Management Plan. It all comes down to how EPA instituted their “Program Levels” when they implemented their RMP Rule. EPA has always said that if your process was…...
How does OSHA’s revised PSM “retail exemption” policy impact my RMP? Read More »
Today OSHA issued another REVISED POSITION in their enforcement of the Process Safety Management Standard. Today they rescinded their previous position and now 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…...
OSHA issues PSM Retail Exemption Interim Enforcement Policy Read More »
The National Board Annual Violation Tracking Report identifies specific violations (per device type) commonly found on five (5) types of pressure equipment during jurisdiction-required inspections. The following data reflects the reporting period of 1/1/2014 – 12/31/2014 as reported by participating member jurisdictions. The Violation Tracking Report indicates problem areas and trends related to boiler and…...
2014 Report of Violation Findings on Pressure Vessels and Pressure Relief Devices (NBBI) Read More »
