This is a very common question when auditing “older plants”, say plants built prior to 1960 (not a specific date with any meaning). For example, during an audit it is discovered that a vessel was built to a RAGAGEP that no one had even heard of or maybe there is NO documentation as to what…...
In March, 2007, the CSB recommended that the American Petroleum Institute1(API) and the United Steelworkers International Union2 (USW) jointly lead the development of an ANSI consensus standard with guidelines for fatigue prevention. The recommendation arose from the investigation of the BP Texas City refinery incident in 2005 (CLICK HERE for additional information on that accident). Their…...
Have you ever heard someone at your facility say, “that part of the process is not covered”? As a process safety professional, this may be our hardest battle in the big scheme of complying with OSHA’s Process Safety Management (PSM) standard and EPA’s Risk Management Plan (RMP) rules. In this article I would like to…...
Splitting the hairs of Process Safety (Battery Limits and Changes) Read More »
Fire-resistant garments are provided to the select few who voluntarily risk life and limb and go into harm’s way. They do it to ensure the safety and security of the rest of us. In this group are members of the all-volunteer military and first responders, from firefighters to the riot control units and SWAT team…...
Standard Number: 1910.132; 1910.132(a) December 18, 2012 MEMORANDUM FOR: REGIONAL ADMINISTRATORS & REGIONAL SOLICITORS FROM: RICHARD E. FAIRFAX, Deputy Assistant Secretary & JOSEPH M. WOODWARD, Associate Solicitor for Occupational Safety and Health SUBJECT: Guidance on Handling Cases Developed Pursuant to the FRC Enforcement Policy Memorandum This is to provide guidance on application of the Enforcement Policy for Flame-Resistant Clothing…...
Guidance on Handling Cases Developed Pursuant to the FRC Enforcement Policy Memorandum Read More »
Federal officials have charged a Georgia transportation company in a 2009 ammonia leak that killed a South Carolina woman. According to court documents, a federal grand jury returned an indictment against the transportation company for alleged violations of the Clean Air Act. The wrong type of hose was used as 7,000 pounds of anyhydrous ammonia…...
Transport Company indicted in SC woman’s ammonia death (Unloading NH3) Read More »
When using an MSDS to comply with the Process Safety Information requirement 1910.119(d)(1)(ii) Permissible exposure limits, is it ACCURATE to use the 8-hr TWA Permissible Exposure Limit (PEL) when the workers work 12-hour shifts? My article last week has stirred a lot of emotions from those who do a lot of “referencing” in their SOPs. So I…...
PSM/RMP Trick Question (Poll) Read More »
Received the most interesting phone call today and there is one more business on the plante that thinks I have completely lost my mind. Their question: “If the manufacturer of a piece of equipment has a recommended maintenance plan, and we do not follow their “recommendation”; how can OSHA issue a citation against a “recommendation”?”…...
A “Manufacturer’s Recommended Practice” is a RAGAGEP Read More »
I have written about the confusion within many industries about their “electrical classification” and what the Recognized and Generally Accepted Good Engineering Practices (RAGAGEPs) allow and do NOT allow. In 2012 we even came across facilities that were using codes from an entirely different industry being applied to their facility, which utilized an entirely different…...
HAZLOCs and Ventilation and Classification Read More »
Over the years we have seen a very large movement to skinny down PSM/RMP operating procedures. At first glance this movement makes a lot of sense; but with any great idea comes pitfalls and it is the pitfalls that I would like to discuss in this posting. Recently we came across the end results of…...
A flaw with referencing info in PSM/RMP Operating Procedures Read More »
This material has been provided by the Nevada Division of Environmental Protection Chemical Accident Prevention Program. This is an EXCELENT SOURCE of reliable information regarding PSM/RMP procedural needs, but it is provided by a STATE AGENCY and may not meet/exceed federal agency expectations. I find it very hard to think that Federal OSHA or EPA would not…...
Understanding the requirements of Standard Operating Procedures (SOP) Read More »
During a PSM/RMP audit this week with my “Partner in Safety”, Unwin Company, Mr. Bob Johnson shared this GREAT worksheet and explanations from the Nevada Division of Environmental Protection Chemical Accident Prevention Program. The purpose of this extensive data form is to assist facilities with the compilation, organization and evaluation of the information that is required to…...
OUTSTANDING Process Safety Information Worksheet Read More »
