OSHA’s Process Safety Management (PSM) Standard states that its requirements do not apply to “retail facilities.” 29 CFR 1910.119(a)(2)(i). On July 22, 2015, OSHA issued a memorandum entitled “Process Safety Management of Highly Hazardous Chemicals and Application of the Retail Exemption (29 CFR 1910.119(a)(2)(i))” (Memorandum). In the Memorandum, OSHA interpreted the term “retail,” as used […]
Here is an inside look at what EPA is considering in their revisions of their Risk Management Plan (RMP) rule. These items are ONLY being CONSIDERED and DISCUSSED and are in NO WAY concrete changes that have been agreed upon. Here are the six KEY areas currently in discussion: Third-party audits (applies to the next
During “routine maintenance”, a process operator was cleaning an inline filter connected to pipework below a thickener tank. He opened the drain valve to verify isolation before undoing four bolts to open the inline filter door. On opening the inline filter door, the operator found the screen/filter full of material. As he pulled the screen/filter out of its
Here are the most up-to-date numbers regarding “RMP Covered” facilities as of 12/20/15), broke down by: Industry Program Level Small vs. Large
Over the past several years car manufacturers have been making the change over to their new GW reduction refrigerant which just happens to be a Category 1 Flammable Gas, thus making this material a Highly Hazardous Chemical in the eyes of OSHA. And when we have over 10,000 pounds of this HHC in our “process”
The simple and short answer is YES. In fact, OSHA covers “dispersal of inventory” in their 1994 Compliance Directive: 29 CFR 1910.119, Process Safety Management of Highly Hazardous Chemicals — Compliance Guidelines and Enforcement Procedures. In this directive OSHA asks and answers the following questions regarding “dispersal of inventory”: Can an employer who keeps threshold
While performing a pressure test on a length of plastic pipe, a pipe blanking cap struck a worker after the crimped connection between the ferrule and pipe failed. The injured worker suffered severe leg and hand injuries and was taken to hospital by ambulance. The incident occurred on the night of 26 November 2015 at
On December 19, 2007, a runaway chemical reaction during the production of a gasoline additive destroyed T2 Laboratories in Jacksonville, Florida, killing four people and injuring 32 others. The blast, equivalent to about 1400 pounds of TNT, damaged buildings and injured office workers hundreds of feet away.
Today we saw a SIGNIFICANT change in OSHA’s attempt to revise their definition of “retail” as it applies to the Process Safety Management Standard. This all went down through channels we would have never imagined… The 2016 Omnibus (spending) bill policy provisions. Yes, that is correct, OSHA got slapped by politicians in a spending bill and oh
From time to time I like to look at RMP data for trends and interesting accidents that we can learn from. As in the past, Anhydrous Ammonia seems to always find its way into my research. Some will say it is because it is by far the most widely used RMP chemical and others will
Many hot work operations are performed by outside contractors, these include cutting, welding, joint soldering, paint removal, reroofing, etc. The tendency is to relax rigid procedures for contractors assuming they know their jobs. However, this practice has produced a discouraging loss history. Hot work by itself is a hazardous process. When outside contractors are involved,
Last week the CSB announce a public meeting regarding the refinery accident in CA back in February. In their announcement the CSB informed us that following the staff presentation, the Board will hear an update on the new process safety management reforms in California from a panel of experts. I have written about these PROPOSED changes
