In the EPA Office of Inspector General’s Semiannual Report to Congress: Oct 1, 2017 – March 31, 2018 we see two “recommendations” regarding the manner in which EPA conducts their Risk Management Plan (RMP) audits and how the OIG feels the process could be improved upon. These are a continuation of improvement from the 2013 […]
For some reason, we have seen a spike in questions and request to assess the applicability of PSM/RMP covered process(s), and this is beyond the typical “can use the Meer decision to get our flammable process out of PSM?” questions. So I thought it would be helpful to publish OSHA’s official interpretation and explanation of
This week I have been working with a new member who has become frustrated with all the different directions and “interpretations” regarding OSHA’s and EPA’s Maximum Intended Inventory requirements. This is my e-mail response – names and titles have been changed to protect the innocent! (LOL) I feel your pain, this one small topic has
The PSM Unit enforces occupational safety and health standards applicable to 14 petroleum refineries and 1,940 chemical plants in California. The chemical plants handle or process 50 million to 120 million pounds of hazardous chemicals every year. Inspections target high-risk facilities and focus on timely, effective abatement. Table 1. Inspections completed during the calendar year
EPA is proposing changes to a final rule, the Risk Management Program (RMP) Amendments (82 FR 4594, January 13, 2017) to better address potential security risks and reasonable consideration of costs. The proposed changes are intended to promote better emergency planning and public information about accidents and maintain the trend of fewer significant accidents involving
In the PSM/RMP world, where Hot Work (HW) permits and all of 1910.252(a) are requirements, we tend to find HW programs, permits, and practices not meeting this critical requirement for SAFE HW. This is caused by a wide array of errors, from the written program/permit omitting this requirement, training not covering this requirement, and/or personnel
On May 17, 2018, EPA’s Administrator signed a proposed rule requesting public comment on several proposed changes to the final RMP Amendments issued on January 13, 2017. EPA is proposing to rescind amendments relating to: safer technology and alternatives analyses, third-party audits, incident investigations, information availability, and several other minor regulatory changes EPA is also
It is the owner’s responsibility to select the applicable code section(s) that apply to the proposed piping installation. Factors to be considered in this decision include: scopes of the code sections; jurisdictional requirements; and the applicability of other codes and standards Each B31 code section is intended to be applied as a whole to a
MEMORANDUM FOR: REGIONAL ADMINISTRATORS THROUGH: RICHARD MENDELSON, Acting Deputy Assistant Secretary FROM: THOMAS GALASSI, Director Directorate of Enforcement Programs SUBJECT: Process Safety Management Retail Exemption Enforcement Policy
Using NFPA 2113 as our RAGAGEP, these items are by far the most common errors we find in our work when FRC is worn in flammable/HAZLOCs work areas:
Recently I came across another real-life example of a “change to facilities that affect a covered process” that was missed in the MOC process and created a significant hazard to the flammable liquids processing area. The change was a new pallet-jack for the process area, and when it came time to purchase the new one,
This tank fire incident is a MUST READ for all SAFTENG members who are in process safety and industrial safety who manage bulk tanks containing hazardous materials. The learnings from this incident investigation are too many to mention, but the investigation got into: Corporate Strategy and Commitment to Safety & Operational Excellence Contractors Engagement Training
