Comparing RMP Level 2 to Level 3 Programs RMP Program Level 2 RMP Program Level 3 §68.48 Safety information (a) The owner or operator shall compile and maintain the following up-to-date safety information related to the regulated substances, processes, and equipment: (1) Material Safety Data Sheets that meet the requirements of 29 CFR 1910.1200(g); (2) Maximum […]
As we are now 20+ years into the PSM standard (16 years for RMP) I think it may be time to revisit the reason for these standards and what OSHA and EPA are trying to drive us to achieve and how our HHC/EHS inventory management plays a HUGE role in this effort. This MII requirement
Have you ever wondered why PSM and RMP require an employer to establish safe upper and lower limits for such items as temperatures, pressures, flows, or compositions in their Process Safety Information and evaluate the consequences of deviating from these limits, including those affecting the safety and health of employees? And then, in the Operating
Current Policy PHMSA supports a practice of no gaps/no overlaps. PHMSA has not changed its policy or inspection approach toward processing facilities. PHMSA has no interest in regulating processing units. OSHA regulates gas processing units. PHMSA and OSHA are in agreement on jurisdictional lines. Neither PHMSA or OSHA are limited by fence lines CLICK HERE
Questions and Answers from PSM Webinar Sept. 29, 2015. Answers provided by Jeff Wanko, PE, CSP, and Safety Engineer in OSHA’s Directorate of Enforcement, Office of Chemical Process Safety in Washington, D.C. Q. Do you have to test the safety equipment annually? A. Under paragraph (j), mechanical integrity, OSHA requires that employers inspect and test process equipment
There are so many learnings in this incident that every single business should analyze these against their current safety systems. Many of the issues that the Chemical Safety Board (CSB) investigation investigation identified are present in many other processing units handling Highly Hazardous Chemicals and Extremely Hazardous Substances. This is a breakdown of the items
As we know, both OSHA’s PSM and EPA’s RMP rule require us to evaluate the hazardous effects of inadvertent mixing of different materials that could foreseeably occur. BOTH standards allow us to use our SDS to comply with 910.119(d)(1) Information pertaining to the hazards of the highly hazardous chemicals in the process. The problem is
Question I am the owner/ operator of a business that maintains Anhydrous Ammonia (AA) at or above the Chemical Facility Anti-Terrorism Standards (CFATS) Screening Threshold Quantity (STQ) for BOTH the treatment of crops and for use as a refrigerant in a cold storage facility. Is my facility eligible to claim the CFATS Agricultural Production
PLEASE NOTE the LOI in which OSHA adopted EPA’s 1% rule was thrown out by the courts so I am NOT 100% sure OSHA can use the 1% rule from EPA in their evaluations of what is a covered process/HHC. The smoke is still rising from OSHA’s recent change on Concentrations of greater than
Each week I get into some really deep discussion regarding Process Safety and it seems that many of these discussions involve changes and whether the change needs an MOC. So I thought it would be a good discussion point for us here to toss around. This scenario actually comes out of a 3-year audit I
DHS provides two options when a facility is bought or sold. Option 1: The buyer may assume the facility ID and the submitted surveys of the previous owner. This option is possible under the following conditions:
Recently OSHA rescinded all their previous LOIs regarding how to calculate your HHC in your process when it is NOT in pure form. Since then I have fielded dozens of phone calls and countless emails asking questions about OSHA’s change and how it impacts their process. OSHA’s new enforcement policy is as follows: In determining
