Chemical Process Safety (PSM/RMP)

Improving the Nation’s Chemical Security Program Statistics as of May 1, 2015 More than 49,000 preliminary assessments were reviewed by DHS from facilities with chemicals of interest 3,348 facilities are currently covered by CFATS More than 3,000 facilities voluntarily removed, reduced, or modified their holdings of chemicals of interest 1,890 visits to assist facilities with…...

This decision covers several interesting items and sets a HUGE precedent for RESPONSIBILITY of PHA and Audit items from the PREVIOUS owners PHAs and Audits.  The decision CONFIRMED that “utilities” within the process, in this case a “positive pressure unit” on a control room ventilation system, is a piece of COVERED EQUIPMENT.  It also establishes…...

This is not the first time I have “beat up” on excess flow valves and the reliance on them as a “safeguard” in a PHA or process design.  Both EPA and OSHA are on record stating their displeasure of claiming these valves as a safeguard.  Now don’t get me wrong, these devices WORK and WORK…...

Christine Baker, Director of the Department of Industrial Relations (DIR), has submitted a legislatively-mandated status report on DIR and Cal/OSHA’s Process Safety Management (PSM) Regulatory Oversight. The report is required pursuant to the Budget Act of 2014 (Provisions 1 and 2 of item 7350-001-3121, Chapter 25, Statutes of 2014). A new assessment on the state’s…...

I am working on getting all of these RMP NOVs posted but found this one especially interesting… XXXXXXXXXX did not address the impact of the lock-out of the factory workers in August 2011 and hiring all new replacement workers.  Such extensive staffing changes could impact the safety and health of the XXXXX workers and should…...

 … Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

A Pressure Vessel subject to Internal Corrosion shall be defined as any metal Pressure Vessel using a processed product that can cause Corrosion, Erosion, Pitting, Cracking, or Deterioration, as defined in Part 2, 3.3 of the National Board Inspection Code. The intent is to verify the vessel is safe to operate.  Pressure Vessels subject to…...

The Department of Homeland Security (DHS) continues to strengthen security at the Nation’s high-risk chemical facilities through the Chemical Facility Anti-Terrorism Standards (CFATS) program.  Chemical Security Program Statistics as of March 2, 2015: More than 48,000 preliminary assessments were reviewed by DHS from facilities with chemicals of interest 3,471 facilities are currently covered by CFATS…...

There are over 75 billion pounds of hazardous chemicals regulated under the RMP rule. Top Five (5) RMP Chemical Quantities… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

As I posted back in August 2014, CAL EPA was looking to make changes to the CALARP rule.  The proposed petition process was rejected but the rest of the package was accepted and were approved by the Office of Administrative Law and took effect on January 1, 2015. The Governor’s Interagency Task Force on Refineries has suggested additional amendments…...

This is an interesting turn of events!  The ALJ upholds most of the citations and then OSHRC vacates them all. This after a 750-pound release of butylene oxide that occurred during a line break activity and was caused by an IMPROPER energy control plan.  One worker was diagnosed with “chemical pneumonia” due to his exposure to the…...