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Recently OSHA rescinded all their previous LOIs regarding how to calculate your HHC in your process when it is NOT in pure form.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
I recently came across a client who for whatever reasons had two (2) Risk Management Plans submitted for the same group of buildings, structures, equipment, installations and substance emitting stationary activities which belong to the same industrial group, which are located on one contiguous property, which are under the control of the same person (or
One of the more common errors we come across in RMPs is the listing of earthquakes, floods, tornadoes and hurricanes as “major hazards”. I can say without hesitation that if your facility is in Omaha, NE that you should not be listing a “hurricane” as a “major hazard” associated with your process. But you very
Each label is REQUIRED to include the following components: Abbreviation for ammonia system components The physical state – either liquid, vapor, or both The marker body containing the word “ammonia” The pressure level – high or low The flow direction Many thanks to Steve Stephenson
OSHA’s PSM standard requires Operating Procedures to address “special or unique hazards” 1910.119(f)(1)(iii) Safety and health considerations:…1910.119(f)(1)(iii)(E) Any special or unique hazards. This item is often not necessary with many of the PSM standard’s Highly Hazardous Chemicals; however, HFO-1234yf has a unique property that falls into this requirement. HFO-1234yf is…
Cases of Stress Corrosion Cracking (SCC) in steel vessels using NH3 have been reported by members of the ammonia refrigeration industry. When NH3 is used as a refrigerant, it is kept at -33° C (-28° F). While it was once believed that NH3 SCC)could not occur at such low temperatures, both practical experience and experimental studies have shown
