The CSB faces two management challenges that, if not addressed, may seriously impede the agency’s ability to achieve its mission efficiently and effectively. Based on our continuous audit work, the EPA OIG has identified two management challenges for the CSB that were not in the fiscal year 2017 report: the lack of authority that […]
Here is an unfortunate incident that draws our attention to operating elevating equipment inside refrigerated spaces. This incident also demonstrates the increased hazards to workers working within these elevated devices, as their means of egress, should there be a chemical release, is GREATLY compromised. Lastly, we should NOT lose sight of the fact that this
For years, PHA’s seemed to always list vessel “relief systems” as a “safeguard” for ALL the HIGH-PRESSURE scenarios involving the vessel. In this article I want to challenge this practice; but to be up front, if you were to look at all my PHA’s I was guilty as sin for doing this very thing. But
As I have stated already this week, I am a HAZOP kind of guy. I have used just about every methodology under the sun over the past 25+ years, and I have come to a personal conclusion that in almost every occasion, a HAZOP would have been the best methodology to utilize for a correct
Earlier this week I posted about how a PHA should document its consideration of the engineering controls and administrative controls failing. And I said back in the 2013 posting; this little requirement is intended to make facilities dig past a single layer of protection and maybe even identify a lack of engineering and/or administrative controls
With all the recent attention being paid to EPA and it’s Risk Management Plan amendments and many of those amendments being rescinded by the new administration, I thought it would be a good time to remind those in the PSM/RMP world, that OSHA has their own wish list (my phrase – not theirs) and some of
In the RMP Amendments rule, EPA added three major provisions to the accident prevention program of Subparts C (for Program 2 processes)and D (for Program 3 processes). These included: A requirement in § 68.60 and § 68.81 for all facilities with Program 2 or 3 processes to conduct a root cause analysis using a recognized
EPA monetized both on-site and off-site damages. EPA estimated total average annual on-site damages of $265.8 million. The largest monetized average annual on-site damage was on-site property damage, which resulted in average annual damage of approximately $205.5 million. The next largest impact was on-site fatalities ($49.8 million) and injuries ($10.5 million). EPA estimated total average
Over the years I have facilitated and participated in hundreds of PHAs from toxics to flammables and even some explosives (although not my thing!). And in doing so, one thing that drives me crazy is the lack of structure in how process deviations are identified and studied/analyzed. I love the HAZOP methodology and hate the
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
