In my Process Safety, HAZMAT, and Emergency Response course, I always walk the students through an exercise to demonstrate just how dangerous chemicals such as Cl2 and NH3 are. So many have come to think that these chemicals are only hazardous when we exceed the OSHA/EPA Thresholds for PSM/RMP. In a space that is 40 […]
The U.S. Chemical Safety Board has released preliminary findings from its ongoing investigation of the toxic chemical release that occurred at a distilled spirits plant in Kansas on October 21, 2016. The CSB’s investigation into the release has identified several shortcomings in the design and labeling of loading stations, as well as adherence to chemical
Facilities subject to the Program 3 Prevention Program requirements in 40 CFR Part 68 must include in their Risk Management Plan the date of the most recent review or revision of hot work permit procedures in Section 7.13. What is considered hot work and what are the requirements related to hot work?
The multiple-fatality explosion on October 17, 2016 explosion and subsequent fires at the german facility has been determined to be caused by a contractor cutting into an incorrect line/pipe containing flammable raffinate. Two employees of the on-site fire department and an employee of a tanker which was anchored in the harbor died in the accident.
One of the most often overlooked requirements for piping installations is the proper leak/pressure testing of the piping BEFORE it is placed into service. The next major issue found, when piping is tested, is the manner in which it was tested. The 2014 and 2016 editions of ASME B31.3 makes it clear that hydrostatic testing
This week EPA’s Administrator signed a proposed rule to further delay the effective date of the RMP rule amendments for 20 months until February 19, 2019. This action will allow EPA to consider several petitions for reconsideration of the RMP rule amendments and take further regulatory action. EPA will hold a public hearing regarding the
I have been given permission to OPEN up a PSM Training course in April to other clients/members. This is a 4.5 day training course and involves field-work, so you will need to bring your PPE (Safety Glasses, Safety Boots, Hard-Hat, and FRC if you have it). The course will be taught with a focus on Category
All workers for building trade contractors at REFINERY FACILITIES must complete a MINIMUM of 20 hours of approved advanced safety training by January 1, 2018, AND are required to do so every two (2) years thereafter. This requirement was added to the California Health and Safety Code in Section 25536.7. To confirm that a worker
As the ballons were filled and the cake was cut, several industries got what they worked so hard to achieve… OSHA can not revise the PSM “retail” definition without going through the Public Rule Making process. But those who take process safety and risk management seriously may be surprised to know that OSHA had already
It amazes me how society, specifically lawyers and politicians, can be so collectively ignorant. With all the change in the political winds some industries are breathing a sigh of relief regarding OSHA’s efforts to redefine “retail” when it comes to the “retail exemption” found in their Process Safety Management (PSM) Standard. For the record, I did
EPA received a petition dated February 28, 2017, from the RMP Coalition, representing several trade associations. The petition requests a reconsideration and request for stay for the RMP rule amendments, published January 13, 2017. On March 13, 2017, EPA’s Administrator convened a proceeding for reconsideration of the RMP rule amendments. On March 16,
