Several months ago I posted an article OSHA publishes DRAFT “Process Safety Management for Small Business Compliance” and how it offered some guidance on how facilities could disperse their inventories of Highly Hazardous Chemicals (HHC) and stay out of or get out of PSM. I have received many e-mails questioning the validity of the material in the DRAFT…...
For the gun owners, you already know what the title means. But for those not quite sure, this is what I mean. When we handle a firearm, loaded or unloaded, we ALWAYS treat it as if it is loaded. This means we NEVER put ourselves in the line of fire, REGARDLESS of the status of…...
Since EPA published their final amendments last month, some in the process safety profession have been in a tizzy over the 3rd Party Audit Requirements. This little revision is going over about as well as OSHA’s revised Hazard Categories. This week I have fielded many calls, emails, and texts from people panicking over this new 3rd…...
It won’t. Both the OSHA PSM standard and the EPA RMP rule aim to prevent or minimize the consequences of accidental chemical releases through implementation of management program elements that integrate technologies, procedures, and management practices. In addition to requiring implementation of management program elements, the RMP rule requires covered sources to submit (to EPA)…...
This week EPA issued two letters explaining the changes to the local coordination requirements and they will advance local preparedness and assist local response officials, as well as the Local Coordination requirements that are included in the final rule. Here’s what EPA said:… Membership Required You must be a member to access this content.View Membership LevelsAlready a...
EPA issued several letters this week clarifying the NEW “public information” requirements in their FINAL AMENDMENTS of their RMP rule. Here are the questions that EPA answered in their letters: What is the process for responding to information requests from the public? How does EPA’s final rule preserve security while enhancing the ability to local…...
EPA issued a letter explaining what incident investigations and root cause Analysis requirement changed from the proposed to final rule and what the final rule requires with regards to incident investigations. Here’s what EPA said:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
“Safer Technology And Alternatives” (STAA) refer to risk reduction strategies developed using a hierarchy of controls that are considered inherent, passive, active, and procedural. This strategy can be applied initially to all design phases and then continuously throughout a process’s life cycle. STAA includes concepts known as inherently safer technologies (IST) or inherently safer design…...
EPA has issued two letters that better clarify what the “Third Party Audit” requirements changed from the proposed to final rule and what the third-party audit requirements actually are. Here’s what EPA said:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
EPA has established the following dates for facility owners and operators to comply with the revised rule requirements:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
EPA issues “letters” on their website that helps clarify many of their rule requirements, much like OSHA’s Letters of Interpretation. This week OSHA issued twenty-one (21) such letters following their FINAL amendments to their Risk Management Plan rule. These two (2) letters address what EPA has done to further the safe storage and handling of Ammonium…...
OSHA cited a refinery in 2008 for failing to inspect a piece of equipment known as the positive pressurization unit (PPU). The refinery contends that this citation is unlawful because the PPU is not encompassed by the relevant regulations. Because this dispute involves the interpretation of a binding regulation promulgated by the agency, we defer…...
