Chemical Process Safety (PSM/RMP)

Conducting a Fire Risk Assessment

The first step to emergency preparedness is defining and analyzing hazards. Although all hazards should be addressed, resource limitations usually do not allow this to happen all at once. Risk assessments are used to establish priorities so that the most dangerous situations are addressed first and those least likely to occur and least likely to…...

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OSHA asking for permission to inspect PSM facilities with fewer than 10 employees

OSHA, combined with our State Plan partners, has approximately 2,200 inspectors responsible for the health and safety of 130 million workers, employed at 8 million worksites around the nation.  Although workplace conditions today are much safer than when OSHA was created, over 4,300 workers are still killed in the workplace each year and millions are…...

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Are my Railcars on site covered under RMP? (Sulphur Trioxide and Flammables/ $21,788 w/ $200,000 SEP)

This is a topic I have written about several times before and EPA has made their position fairly clear in their RMP Q&A’s.  SAFTENG members can CLICK HERE to read the summary of the EPA Q&A’s regarding railcars that are NOT attached to a mode of transport (i.e. locomotive).  These railcars that sit out on…...

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A look at what RMP Facilities can expect from EPA in 2014

Inspect at least 4% of the total number of RMP-regulated facilities during FY 2014. Of these inspections, at least 36% should be conducted at high-risk RMP facilities, using the list derived from established high-risk criteria and provided by headquarters to regional offices at the beginning of the fiscal year. Regional program managers may, after consultation…...

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OSWER Risk Management Program Evaluation Scoping Project (EPA’s path forward in determining who should get an RMP inspection)

  The Risk Management Program (RMP) is implemented by the Office of Emergency Management (OEM) in EPA’s Office of Solid Waste and Emergency Response (OSWER). EPA and state and local implementing agencies conduct inspections at RMP facilities to determine compliance with RMP regulatory requirements, but because resources for conducting inspections are limited, within the past…...

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OSWER Risk Management Program Evaluation Scoping Project (EPA’s path forward in determining who should get an RMP inspection) Read More »

CAA 112(r) Inspections – What to expect & suggestions from the inspectors

This is an EXCELLENT presentation from EPA (4/2013) on doing RMP Inspections @ Ethanol Facilities. Although the presentation appears to be specifically for Ethanol facilities, it’s “suggestions and tips” WILL apply to any RMP covered facility (and for PSM-covered facilities as well). Some of the interesting revelations are: 1) EPA uses Google and Bing Satellite…...

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EPA’s Office of Inspector General says Improvements Needed in EPA Training and Oversight for RMP Inspections

This is why I have oh little faith in our government to protect us!!!  Enforcement can NOT and should NOT be the driver behind improved environmental, health and safety performance!  The hypocrisy in this report, aimed at the agency tasked with enforcing the very rule they wrote is nothing short of pathetic.  Sitting here I…...

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Pipeline fails because deteriorated coating, ineffective cathodic protection, and the failure to detect the corrosion because the pipeline was not inspected or tested after 1988

Does your process have any “underground piping”?  We do not see this design in newer process designs, but in years past – putting pipe underground seemed like a good idea.  This NTSB report does an excellent job of breaking down the failure modes of underground piping.  The National Transportation Safety Board determined that the probable…...

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Pipeline fails because deteriorated coating, ineffective cathodic protection, and the failure to detect the corrosion because the pipeline was not inspected or tested after 1988 Read More »

PSM Inspection Data UPDATE

In June I will be presenting with my good friend and safety colleague Jonathan Zimmerman at the ASSE Conference in FL.  Our presentation is “Process Safety Management Best Practices, Lessons Learned and Enforcement Trend”. Here is a peak at some very interesting data regarding PSM inspections from May 26, 1992 – February 26, 2014. Stop by…...

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Massachusetts 527 CMR 33.00: Hazardous Materials Process or Processing (UPDATED)

The following has been updated to resolve erroneous or incomplete data with reference to Category 2 and 3 Information and expanded resources for Category 1 compliance. This memorandum replaces the November 1, 2013, memo on the same topic. DFS apologizes for any confusion on the matter. We have passed the final deadline for permits to…...

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The 2013 National Board Incident Report (Based on 2002-2008 OSHA Data)

Before OSHA reports are cleared and posted to its database, each summary undergoes a thorough investigation, revision, and screening process by OSHA, which can delay posting up to 5 years. For those reasons, the National Board has elected to research summaries that are greater than five years old. National Board began with years 2002-2007, and…...

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Relief Valve (RV) Header vs. Directly to Atmosphere

It seems these days that having a relief valve header is the way to go; but why is that? Why are so many businesses deciding an “RV header” is the way to go with their RV Design Basis? In the process safety world, a facility is required to have a “relief design basis” and the…...

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