Chemical Process Safety (PSM/RMP)

OSHA loses their battle to redefine “retail” in the PSM Standard (1910.119)

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 […]

RMP Accident Data (2006-2016)

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

Catastrophic Failure of 500 ton Atmospheric Refrigerated Anhydrous Ammonia Tank (2016)

11/22/2017 UPDATE  – Nice write-up Dap-1 Ammonia Tank Explosion: Safety and Security Concerns in Chemical Process Plant in Bangladesh Two DAP officials found guilty – an engineer and the general manager of the plant were found responsible for the accident.  The accused have been found guilty of negligence in duty as they did not inspect the safety

Do I have to count the quantities of my RMP covered chemicals in railcars sitting on my site?

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

FATAL Hotwork Explosion @ pipeline station ($1.6 million for failure to follow facility procedures)

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

HFO-1234yf refrigerant may end up in New Zealand Refrigerators and Home ACs

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

California Governor’s Office of Emergency Services extends CalARP Program 4 written comment deadline

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.

Can a facility alter its highly hazardous chemical storage practices to avoid PSM?

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

OSHA publishes DRAFT “Process Safety Management for Small Business Compliance”

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

Ammonia Refrigeration, Diffuser Tank and Uniform Mechanical Code (UMC)

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

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