In our line of work we come across a lot of mechanical ventilation systems that are intended to control/reduce quantities of hazardous gases/fumes/vapors in processing/work/storage areas. And in many cases the facility will hand us a document from a designer/contractor that shows the ventilation system has fans that can meet the CFM prescribed in their […]
This week OSHA issued a REVISED PSM NEP. This instruction describes an updated initiative by OSHA. Under the previous related instructions, OSHA conducted inspections of facilities covered by OSHA’s PSM standard either through an instruction specific to petroleum refineries or an instruction related to all other PSM covered chemical facilities excluding petroleum refineries. This REVISED instruction is applicable
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:
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:
“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:
EPA has established the following dates for facility owners and operators to comply with the revised rule requirements:
