Chemical Process Safety (PSM/RMP)

Emergency Response Program (ERP) requirements differ for PSM and RMP

Although the RMP Prevention Plan requirements for Program 2 and 3 very much mirror OSHA’s PSM requirements, the emergency response program requirements found in 68.95 Emergency Response Program go above and beyond the requirements of 1910.119(n) Emergency planning and response.  OSHA’s 1910.119(n) Emergency planning and response directs us to comply with 1910.38 and 1910.120. And although EPA enforces 1910.120…...

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Control the amount of scaffolding permitted in a process area?

I recently had some conversations with fellow safety and fire professionals regarding scaffolding erected in their process units. There seemed to be a lot of scaffolding and very little activity on it, so I asked the question… is there a limit on the amount of surface area that can blanket process equipment to the point…...

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The RAND Corporation memo for the CA-OSHA Process Safety Review

A major explosion at the Chevron refinery in Richmond California in August 2012 resulted in no fatalities and led 15,000 people in the community to seek medical attention. That event spurred the Governor to establish a Task Force to examine what steps should be taken to improve refinery safety in the State. The RAND Corporation…...

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Draft Report of the Interagency Working Group on Refinery Safety – Improving Public and Worker Safety at Oil Refineries

In the aftermath of a serious chemical release and fire at Chevron’s Richmond oil refinery in August, 2012, the Brown Administration formed an Interagency Working Group to examine ways to improve public and worker safety through enhanced oversight of refineries, and to strengthen emergency preparedness in anticipation of any future incident. The Working Group consisted…...

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PHMSA Safety Advisory – Heating Railcars

You may be aksing why I posted this in the PSM/RMP Section; simple, all of the incidents in this alert occurred in a chemical processing area, even though they may have not been covered by PSM/RMP, they no less occurred in processing areas!  In response to the findings from an NTSB investigation, PHMSA is issuing…...

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Preventive Hazard Evaluation for Process Safety (Massachusetts Office of Technical Assistance Advisory)

The Massachusetts Fire Code hazardous material processing regulation (527 CMR 33) requires a hazard evaluation or limited process safety program for many companies that have never faced this requirement before, (though many companies have been essentially performing these tasks as good practice). Many companies covered by this regulation must now document that a hazard evaluation…...

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Seven Keys to Surviving a Chem NEP Audit (John Newquist)

MANY THANKS to John for sharing this with his group!  John is now retired from OSHA but was Region V’s Assistant Regional Administrator for years.  He is one fine safety professional! Nfpa Process Safety Management and OSHA 6 8 2013 from John Newquist… Membership Required You must be a member to access this content.View Membership...

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OSHA reaches settlement agreement with Food Company to protect workers from NH3

A large food company has signed a settlement agreement with OSHA to protect workers at five (5) of its facilities from the release of anhydrous ammonia (NH3) from refrigeration systems.  The agreement protects workers at Idaho, Arkansas, Missouri and Ohio facilities. It requires the company to implement controls to reduce hazards associated with the release…...

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RAGAGEPs and “the numbers”

The use of Recognized and Generally Accepted Good Engineering Practices (RAGAGEPs) has become a common occurrence since OSHA’s Process Safety Management standard and EPA’s Risk Management Plan rule came out in the 1990’s  Some professionals have come to hate RAGAGEPs and wish for the good ole days when OSHA promulgated prescriptive standards like 1910.23; and…...

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DHS CFATS Update as of June 6, 2013

The Chemical Facility Anti-Terrorism Standards (CFATS) program statistics as of June 6, 2013… 44,000 preliminary assessments were reviewed by DHS from facilities with chemicals of interest  4,331 facilities are currently covered by CFATS  Over 3,000 facilities voluntarily removed, reduced, or modified their holdings of chemicals of interest  1253 visits to assist facilities with CFATS compliance 469 Security Plans authorized  125 Security Plans approved following an onsite inspection… Membership...

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