We don’t see this often, so I feel it is worthy of posting this RMP Citation. I have written several articles about this and posted a couple of citations. This one was just posted this week… Process Safety Information [40 C.F.R. 68 .65(c)(l)(iii)] – $300 [Facility] failed to include quantities containing regulated substances purchased for its facility…...
On October 8, 2015, a pipeline facility in LA experienced a reportable incident that resulted in a series of explosions, fire, four fatalities, two injuries, evacuations of nearby residences and closure of a state highway. Representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS) Southwest Region (SWR), responded to…...
New Zealand’s EPA is seeking submissions on an application to import a heat transfer gas to be used for refrigeration and air conditioning. The gas – HFO-1234yf – is for use in refrigeration and air conditioning systems in commercial and domestic settings, including in cars. The applicant, Honeywell International Inc, has applied to import HFO-1234yf…...
The California Governor’s Office of Emergency Services published a Notice of Proposed Action in the July 15, 2016 edition of the California Regulatory Notice Register (Register 2016, No. 29-Z, p. 1207) concerning the CalARP Program 4. The original comment period deadline was August 29, 2016. The Office is extending the written comment deadline to September 15, 2016…....
Yes. When OSHA enacted the PSM requirement, it did so in an effort to eliminate or minimize catastrophic incidents involving highly hazardous chemicals. PSM programs are risk reduction strategies. When implemented correctly, reducing storage inventories of highly hazardous chemicals and isolating stored quantities in distinct facility areas are acceptable risk reduction strategies. Employers at storage…...
UPDATED 4/19/2017 – OSHA has published the approved edition https://www.osha.gov/Publications/OSHA3908.pdf OSHA has published a DRAFT revision of their OSHA 3132, Process Safety Management. This new version is NOT meant to be a replacement for OSHA 3132, but instead meant to be a companion to the original OSHA 3132 specifically for small businesses that may be impacted by…...
The diffuser tank discussion continues and Peter Thomas, P.E. from Resource Compliance, Inc. was kind enough to offer us the following insight as to when a diffuser tank would be required. In most of my postings, I reference the International Fire Code (IFC) and International Mechanical Coden(IMC) quite often, but the Uniform Mechanical Code (UMC) is a…...
This past week I was having a conversation with my friend and fine PSM professional Brian Chapin @ RCE and our discussion turned to diffuser tanks. Having been involved in several design and install projects over the past several years, getting to know a little something about diffuser tanks comes with the territory. But one of my…...
This incident shows us that just because a pipe contains a chemical that may not be included in a PSM/RMP program, it does not mean the level of risk is any less. This explosion was caused by construction workers using a cutting torch to remove old piping from a boiler room and cut into a…...
2016 will go down as the year OSHA and EPA tried to revamp their PSM and RMP rules for handling Highly Hazardous Chemicals (HHC) and Extremely Hazardous Substances (EHS). We have even seen Congress get into the act of blocking OSHA from enforcing PSM on fertilizer distributors. All the while, our friends to the north have…...
For years, NFPA 70, the “National Electric Code” has exempted Engine Rooms/Mechanical Rooms for refrigeration processes using Anhydrous Ammonia from having to be Electrically Classified Hazardous Locations (HAZLOC) as long as the room had “adequate ventilation”. The exemption in NFPA 70 has always been sort of vague and referenced the ventilation requirements in ANSI/ASHRAE 15-1994, Safety…...
Recently at a Compliance Assistance conference, OH-EPA presented on EPA’s Risk Management Plan and revealed some interesting data. One thing to state up front is that Ohio EPA is one of thirteen (13) states that has been delegated to enforce 40 CFR Part 68 within the state of Ohio. With that comes a snap shot…...
