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:
EPA has established the following dates for facility owners and operators to comply with the revised rule requirements:
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
Delek purchased an oil refinery located in Tyler, Texas from Crown Central and took possession on April 29, 2005. Beginning in February 2008, OSHA conducted a four-month inspection of the refinery and issued a citation on August 18, 2008, finding violations of 29 C.F.R. § 1910.119 and other regulations that are not at issue here.
Safeguarding is the provision of protective measures to minimize the risk of accidental damage to the piping or the harmful consequences of possible piping failure. In most instances, the safeguarding inherent in the facility (the piping, the plant layout, and its operating practices) is sufficient without the need for additional safeguarding. In some instances, however,
Three distinct elements of a flanged joint must act together to provide a leak-free joint: the flanges, the gasket, and the bolting Factors that affect performance include the following:
The revisions to 2015 IFC, Section 606.12 clarify the code requirements and add references to two (2) International Institute of Ammonia Refrigeration (IIAR) standards and one American Society of Heating, Refrigerating and Air-Conditioning Engineers, Inc. (ASHRAE) standard for design and operation of ammonia refrigeration systems. This edition of the IFC also pulls in a lot
In an effort to provide you with the new language I have presented this material, cut from EPA’s early release document which was several hundred pages. Here is what is actually changing in the rule:
My good friend and Ammonia Refrigeration PSM extraordinaire, Brian Chapin with RCE, has allowed me to share his work here. I figured I could not have done any better on this breakdown so I asked if he minded I share this at SAFTENG, we lucked out and he said yes! This is an excellent breakdown,
EPA recently updated their Risk Management Plan (RMP) rule in several key areas: 1) accident prevention program requirements, 2) emergency response requirements, and 3) improvements to the public availability of chemical hazard information. In this article, I will break down the NEW Emergency Response requirements and some serious barriers to fully complying with these new requirements.
EPA in response to Executive Order 13650, is amending its Risk Management Program regulations. The revisions contain several changes to the accident prevention program requirements including an additional analysis of safer technology and alternatives as part of the process hazard analysis for some Program 3 processes, third-party audits and incident investigation root cause analysis for
