Chemical Process Safety (PSM/RMP)

The National Board of Boiler and Pressure Vessel Inspectors has released its First Quarter Report of Violation Findings for 2015. The data captures problem areas and trends related to boiler and pressure vessel operation, installation, maintenance, and repair; and also identifies problems before unsafe conditions occur. This report serves as an important source of documentation for…...

A recent fatality at an ammonia refrigeration process in Canada points to a potential weakness in “contractor safety” at facilities with active process safety management systems in place. PSM/RMP facilities regularly get “safety information and data” from their contractors; this information is usually the contractor’s OSHA injury/illness rates, experience modification rate, etc.  But many PSM/RMP…...

A fire at the Chevron refinery in Richmond in August 2012 raised public concern about refinery safety and emergency response in California. Following a directive from the Governor’s February 2014 report on “Improving Public and Worker Safety at Oil Refineries,” CalEPA formed the Interagency Refinery Task Force (IRTF).  The IRTF membership includes ten state agencies,…...

The U.S. Environmental Protection Agency (EPA) invites small businesses, governments, and not-for-profit organizations to participate as Small Entity Representatives (SERs) for a Small Business Advocacy Review (SBAR) Panel. This panel will focus on the Agency’s development of a rule that proposes to modify the current Risk Management Plan (RMP) regulation to reduce the likelihood of…...

This is a follow up to my July 2013 article “Making the case my PSM/RMP covered process complies with RAGAGEPs (Piping)”.  With OSHA’s recent memo on “RAGAGEP in Process Safety Management Enforcement” I have received renewed request to explain how a facility can demonstrate their vessels/tanks comply with RAGAGEP(s).  Here it goes:… Membership Required You...

When it comes to EPA’s Risk Management Plan rule, the state of California made significant modifications to the RMP rule.  Basically, California replaced the Risk Management and Prevention Program with the California Accidental Release Prevention (CalARP) Program on January 1, 1997. The CalARP Program is very similar to the EPA’s Risk Management Program with the…...

PLEASE NOTE the LOI in which OSHA adopted EPA’s 1% rule was thrown out by the courts so I am NOT 100% sure OSHA can use the 1% rule from EPA in their evaluations of what is a covered process/HHC. Last week OSHA changed their position in how they will handle “mixtures” of those chemicals listed in…...

MEMORANDUM FOR: REGIONAL ADMINISTRATORS AND STATE PLAN DESIGNEES THROUGH: DOROTHY DOUGHERTYDeputy Assistant Secretary FROM: THOMAS GALASSI DirectorDirectorate of Enforcement Programs SUBJECT: Process Safety Management of Highly Hazardous Chemicalsand Covered Concentrations of Listed Appendix A Chemicals This memorandum revises OSHA’s enforcement policy on the concentration of a chemical that must be present in a process  for…...