Last week I posted a June 2016 OSHRC decision in which an Administrative Law Judge (ALJ) sided with OSHA on a number of PSM citations regarding a fatal boiler explosion that occurred within a PSM-covered process. Since that posting, I have received dozens of e-mails asking for more explanation and how I suggest managing this…...
This case is not final orders of the Review Commission as it is pending Commission Review! This decision can have HUGE impacts throughout the PSM/RMP community, as many covered processes are “interconnected” to a boiler and many may also be “co-located” such that a boiler explosion could impact the covered process. This case involved a boiler…...
This week I was privileged to be able to present as ASSE’s Safety 2016 on a topic near and dear to me… Line Break/Process Opening. In our presentation, we mentioned “Routine vs. Non-Routine Openings” and how we manage these different openings. One of the requests we received afterward was for “routine openings” that resulted in…...
This is the latest version of the Chemical Reactivity Worksheet (CRW) 4.0.0, which was posted on March 3rd, 2016 . Follow these instructions for downloading, installing, and running the CRW. NOTE: With the release of CRW 4.0 in March 2016, the ongoing management and distribution of the CRW have been transitioned to The Center for…...
Every once in a while we come across process vessels that are operating well above 15 psi and yet the vessel has no recognized design criteria and is far from being an ASME “coded vessel”. Most of the time the client is happy we discovered this, but there are those who will always challenge the…...
Thanks for everyone’s positive feedback. As promised here are the files we promised…… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
One of the top questions I receive is asking about how NFPA 704 ratings play into the application to OSHA’s Process Safety Management standard and EPA’s Risk Management Plan rule. I hope to clarify any confusion this NFPA 704 application may be causing, as YES – the NFPA 704 does have a role in determining if…...
OSHA has started its Small Business Advocacy Review Panel in order to get feedback on several potential revisions to OSHA’s Process Safety Management Program (PSM) standard. The modernization topics OSHA is considering stem from industry best practices, inspection history, stakeholder comments received in response to OSHA’s 2013 Request for Information and lessons learned from accidents…...
The Committee recommends $552,787,000 for the Occupational Safety and Health Administration [OSHA], which is responsible for enforcing the Occupational Safety and Health Act of 1970 in the Nation’s workplaces. The Committee continues bill language to allow OSHA to retain course tuition and fees for training institute courses used for occupational safety and health training and education…...
Readers of my Incident Alerts may remember this NH3 fatality from September 2012… AMMONIA FATALITY Winery worker dies after ammonia exposure (a worker at a winery has died after being exposed to ammonia – one of the workers accidentally opened a wrong valve and released ammonia into a confined area – the man was one of six workers exposed…...
Many working professionals may not be aware that some states and territories have their own OSHA and others are covered by Federal OSHA. In fact, twenty-six states, Puerto Rico, and the Virgin Islands have OSHA-approved State Plans. Twenty-two State Plans (21 states and one U.S. territory) cover both private and state and local government workplaces. The…...
For those living the dream of being a process safety professional know that one of the fundamental decisions we eventually have to make is how will we “class” our PSM/RMP covered process piping. For almost all of us, the best Piping Inspection RAGAGEP will be API 570, Piping Inspection Code and this RAGAGEP has a…...
