On the night of October 23, 2009, a large explosion occurred at the Caribbean Petroleum Corporation (CAPECO) facility in Bayamón, Puerto Rico, during offloading of gasoline from a tanker ship, the Cape Bruny, to the CAPECO tank farm onshore. A 5-million gallon aboveground storage tank (AST) overflowed into a secondary containment dike. The gasoline spray […]
A couple of weeks ago, I wrote about how the Process Safety Information (PSI) “Safe Upper and Lower Limits” will differ from those “Safe Upper and Lower Operating Limits” found in our Operating Procedures. The article needed to be written as it received over 10,000 hits, and the e-mails continued with positive comments and more
PSM Retail Exemption Interim Enforcement Policy Employer(s) with employee(s) exposed to PSM-covered processes formerly exempted under OSHA’s 1992 interpretation of “retail facility” now must comply with the requirements of 29 CFR 1910.119 if the facility, or portion of the facility processing the highly hazardous chemical, does not fall into the North American Industrial Classification System
There’s a reason why both OSHA and EPA have requirements to CONTROL the entry of contractors into our covered process(s), their presence, and their exit from the process. It is so IMPORTANT, we find two (2) places in the standards that require this kind of CONTROL over contractors who wish to work ON, IN, or
One of the most popular PSM requests I get is for an example of a “change to facilities that affect a covered process”. In this article, I hope to provide an actual example and how a “change to facilities” can affect an ammonia refrigeration facility. OSHA’s PSM standard states the following about managing changes… (l)
CLICK HERE for the pdf. Many thanks to the CALOSHA Pressure Vessel Unit for sharing.
The recent change in OSHA’s PSM definition of a “retail facility” is having a large ripple effect all the way across EPA’s RMP rule. As I wrote about in “How does OSHA’s revised PSM “retail exemption” policy impact my RMP?” this change, thought by many as minor – thus the six-month compliance window for these
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
