Chemical Process Safety (PSM/RMP)

OR-OSHA announce PSM Inspection Selection Protocol (VPP Sites exempted)

Oregon OSHA has published their PSM NEP which focuses on processes with Ammonia, Chlorine, and Formaldehyde.  The NEP also EXEMPTS VPP sites from any inspections under their Emphasis Program.  To make the most effective use of its limited resources, OR-OSHA will use annual data gathered by the Oregon Office of State Fire Marshal (OSFM) Hazardous…...

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The history and explanation of Anhydrous Ammonia’s dual NFPA 704 Flammability Ratings

The changes in NH3’s flammability ratings in NFPA’s 704 ratings comes down to the difference between ammonia’s inherent chemical properties and specific regulatory overrides designed for enclosed refrigeration systems. Strictly speaking, the base chemical rating for pure anhydrous ammonia is a “1”. However, the International Mechanical Code (IMC) and the International Institute of Ammonia Refrigeration (IIAR)…...

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NH3 Fatality – Process Opening/Line Break Gone Bad!

A factory refrigeration technician who lost his lungs to an anhydrous ammonia leak has no case against his employer, a poultry plant in N.C.  The incident in June 2009 killed one refrigeration technician and injured another refrigeration technician and their supervisor. The injured refrigeration technician was in a coma for four to five months and had to have…...

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OSHA PSM Letter – Agricultural Retailers Association, et al. v. United States Department of Labor

VIA ELECTRONIC FILING May 5, 2016 Mark J. Langer, Clerk The United States Court of Appeals District of Columbia Circuit 333 Constitution Ave., NW Washington, DC 20001 Re. 28(j) Letter – Agricultural Retailers Association, et al. v. United States Department of Labor, et al., Nos. 15-1326 and 15-1340 Dear Mr. Langer: Respondents write to advise the…...

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OSHA’s behind the scenes political battle with PSM enforcement

Dear Member of Congress, I am writing to respond to concerns expressed regarding the Occupational Safety and Health Administration’s (OSHA) July 2015 retail exemption interpretation and to update you on regulatory action OSHA is taking in this matter.   … Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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OSHA issue Enforcement Policy Memo to Regional Administrators on “RAGAGEP in Process Safety Management Enforcement”

May 11, 2016 MEMORANDUM FOR: REGIONAL ADMINISTRATORS THROUGH: DOROTHY DOUGHERTY, Deputy Assistant Secretary FROM: THOMAS M. GALASSI, Director Directorate of Enforcement Programs SUBJECT: RAGAGEP in Process Safety Management Enforcement   NOTE:  much of the emphasis has been added by me This enforcement policy addresses the Process Safety Management (PSM) Standard’s recognized and generally accepted good engineering practices (RAGAGEP) requirements. Enforcement activity,…...

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OSHA Clarifies the Flammable Atmospheric Storage Tank PSM Exemption and why they seek to change it

The existing PSM standard applies in part to processes involving a flammable liquid or gas on site in one location in a quantity of 10,000 pounds or more. However, the existing PSM standard contains an exemption for “[f]lammable liquids stored in atmospheric tanks or transferred which are kept below their normal boiling point without benefit…...

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Process Safety Management SER Background Document (May 2016)

As an initial step, and prior to publication of any proposed changes to existing rules or enforcement policies, OSHA is convening a Small Business Advocacy Review Panel (“SBAR Panel”) in accordance with the Regulatory Flexibility Act, or RFA (Sections 601 through 612 of Title 5 of the United States Code). This Panel consists of members from OSHA, the…...

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Process Safety Management Small Business Regulatory Enforcement Fairness Act (SBREFA) SER Background Document (May 2016)

The Process Safety Management (PSM) standard is intended to prevent or minimize the consequences of catastrophic releases of highly hazardous chemicals (HHCs). It requires employers to adopt a comprehensive management program that integrates technologies, procedures, and management practices to help assure safe and healthy workplaces. OSHA is considering revisions to the PSM standard, including changes…...

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UPDATE on OSHA’s PSM Revisions (May 2016)

Last week OSHA shared an update on where they are at with their desired revisions to the PSM standard (1910.119).  Some of the potential PSM Revisions include:   Atmospheric Storage Tanks Oil and Gas-Well Drilling, Servicing, and Production Chemical Reactivity Safer Technology and Alternatives Additions to Appendix A Chemicals Dismantling/Disposal of Explosives Define/Updating RAGAGEP Mechanical…...

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Pressure Differential Between Safety or Safety Relief Valve Setting and Pressure Vessel Operating Pressure (NBIC)

We have seen this far too often… operating ranges that are too close to RV set points.  Here is some excellent guidance from a great pressure vessel RAGAGEP, the National Board (NBIC-Parts 1-3) on how to establish the DESIGN characteristics for a pressure vessel based on the OPERATING PARAMETERS the vessel will be operating in……...

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