Chemical Process Safety (PSM/RMP)

Is “dispersal of inventory” an accepted method to maintain inventories BELOW PSM/RMP Thresholds?

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 […]

OSHA’s PSM Retail Exemption, Anhydrous Ammonia, and 2016 Omnibus Bill

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

FM Global UPDATES their Hot Work Fire Statistics involving contractors (2013)

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,

A chance to hear the reasoning/rationale behind Cal/OSHA’s PROPOSED rules for “PSM @ Refineries”

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

Legal UPDATE on OSHA’s interpretation of a “retail facility”

There is a LOT of chatter about OSHA’s revised “retail facility” LOI and what it means to some industries and the timing the courts could play in the outcome.  The magazine AGProfessional has published a VERY NICE update on the legal proceedings and what lies ahead for the Agricultural Retailers Association (ARA) and The Fertilizer Institute (TFI)

EPA memorandum to establish EPA policy on the effect of the OSHA’s reinterpretation of the “retail exemption”

EPA has issued a memorandum to all Regional Administrators to establish EPA policy on the effect of the OSHA’s reinterpretation of the “retail exemption” under the Process Safety Management (PSM) standard.  The RMP regulation contains a provision at section 68.190(b)(7) requiring facilities to revise and update risk management plans within six (6) months of a

Report of Violation Findings for Third Quarter 2015 (NBBI)

The National Board of Boiler and Pressure Vessel Inspectors has released its Third Quarter Report of Violation Findings for 2015.  The data captures problem areas and trends related to boiler and pressure vessel operation, installation, maintenance, and repair; and also identifies problems before unsafe conditions occur.  This report serves as an important source of documentation

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