Chemical Process Safety (PSM/RMP)

National Board’s 2015 First Quarter Violation Report (NBBI)

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…...

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Our contractors and their “subs”

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…...

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Proposed Regulatory Changes to Improve Oil Refinery Safety (CalEPA)

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,…...

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Plant Aging Study (UK’s HSE COMAH )

Between 1996 and 2008 it is estimated that there have been 173 loss of primary containment (LOPC) incidents reported in RIDDOR that can be attributable to ageing plant. This represents 5.5% of all loss of containment events. The limited information provided in RIDDOR about the underlying causes means that it is difficult to identify which…...

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Will our cars soon be miniature PSM/RMP covered processes due to the “mildly flammable” refrigerant they will contain?

No, your car will not be a “covered process” under PSM, but only because it will NOT have 10,000 pounds of this Category 1 Flammable Gas.  But this new refrigerant is coming and it will be in your car’s air conditioning very soon!  A lot of the literature for this new refrigerant uses phrases like…...

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Will our cars soon be miniature PSM/RMP covered processes due to the “mildly flammable” refrigerant they will contain? Read More »

EPA Seeks Input on Modernizing the Risk Management Plan (RMP) Rule

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…...

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Making the case my PSM/RMP covered process complies with RAGAGEPs (Vessels)

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...

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EPA RMP vs. CalARP (CA Accidental Release Program)

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…...

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OSHA’s presentation on RAGAGEP Enforcement from 2015 ASSE

Here is the presentation that Jim Lay, P.E., from OSHA’s Office of Chemical Process Safety & Enforcement Initiatives did last week @ ASSE’s Annual Conference.  He did this presentation the same day OSHA rolled out their new enforcement policies on chemical mixtures and RAGAGEP enforcement.  The presentation covers RAGAGEP Background, Early recognition of RAGAGEP, RAGAGEP…...

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How could OSHA’s move to EPA’s “1% rule” for mixtures change at facilities handling OSHA PSM HHC mixtures?

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…...

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How could OSHA’s move to EPA’s “1% rule” for mixtures change at facilities handling OSHA PSM HHC mixtures? Read More »

What the heck is “partial pressure” and how do I calculate it for my PSM/RMP mixture?

With OSHA’s change last week in how PSM applies to “mixtures” of HHCs I have received a number of questions about “partial pressure” and what impact it can have on whether my process is covered or not?  EPA has been using “partial pressure” of 10 mm Hg for their mixture applicability rule since 1999, but…...

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OSHA memo on Process Safety Management of Highly Hazardous Chemicals and Covered Concentrations of Listed Appendix A Chemicals (same as EPA’s 1% Rule)

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…...

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