Chemical Process Safety (PSM/RMP)

This is an investigative report of the March 16, 2016 hydrogen/oxygen explosion at the University of Hawaii at Manoa campus (UH), in which a postdoctoral researcher lost her arm and sustained burns to her face and temporary loss of hearing. The postdoctoral researcher was working in a laboratory at the Hawaii Natural Energy Institute in the Pacific Ocean…...

The Occupational Safety and Health Administration (OSHA) and the Environmental Protection Agency (EPA) urge employers (owners and operators) to conduct a root cause analysis following an incident or near miss at a facility.1 A root cause is a fundamental, underlying, system-related reason why an incident occurred that identifies one or more correctable system failures.2 By conducting a root cause analysis…...

In my upbringing in the chemical industry I had the opportunity to work with some outstanding engineers; too many to mention by name.  These men and women took time out of their busy schedules to teach me process safety.  One of these engineers was very strict about his process piping and every engineer in the…...

Enforcement Delay Notice Note: OSHA is NOT implementing the July 2015 memo on the retail exemption. The Department is considering its options in light of the D.C. Circuits decision in Agricultural Retailers Association et al. v. United States Department of Labor and OSHA (D.C. Cir. Case Nos. 15-1326 and 15-1340)…. Membership Required You must be...

Metrics are measures that are used to evaluate and track the performance of a facility’s process safety management program. For facilities that handle highly hazardous chemicals, metrics can be used to quantify how a process has performed historically, how it might perform in the future, and where improvements can be made to keep workers safe…....

Earlier this year, the Department of Homeland Security (DHS) temporarily suspended the requirement to submit Chemical Facility Anti-Terrorism Standards Top-Screens and Security Vulnerability Assessments (SVA) in order to allow for a phased rollout of the new Chemical Security Assessment Tool (CSAT) 2.0 surveys and enhanced risk tiering methodology. On October 1, 2016, the requirement to…...

This week Senator Barbara Boxer (D-CA), Ranking Member of the Environment and Public Works Committee, sent a letter to the Environmental Protection Agency (EPA) calling on the agency to strengthen the proposed revisions to the Risk Management Plan rule. Specifically, she wants the following prevention requirements added to the rule before it is finalized (apparently…...

Friday morning (9/23/16) the United States Court of Appeals, For the DISTRICT OF COLUMBIA CIRCUIT announced that OSHA could not redefine “retail” using a Letter of Interpretation (LOI) or Memorandum, OSHA would have to go through the Notice of Public Rule Making (NPRM) in order to redefine the term.  Ironically, it was a 1995 LOI that actually…...

In the last 10 years, RMP data show that there have been more than 1,500 reportable accidents, about 500 of which had off-site impacts. These accidents are responsible for nearly 60 deaths, some 17,000 people were injured or who sought medical treatment, almost 500,000 people evacuated or sheltered-in-place and more than $2 billion in property…...