No, your car will not be a “covered process” under PSM, but only because it will NOT have 10,000 pounds of this Category 1 Flammable Gas. But this new refrigerant is coming and it will be in your car’s air conditioning very soon! A lot of the literature for this new refrigerant uses phrases like […]
The U.S. Environmental Protection Agency (EPA) invites small businesses, governments, and not-for-profit organizations to participate as Small Entity Representatives (SERs) for a Small Business Advocacy Review (SBAR) Panel. This panel will focus on the Agency’s development of a rule that proposes to modify the current Risk Management Plan (RMP) regulation to reduce the likelihood of
This is a follow up to my July 2013 article “Making the case my PSM/RMP covered process complies with RAGAGEPs (Piping)”. With OSHA’s recent memo on “RAGAGEP in Process Safety Management Enforcement” I have received renewed request to explain how a facility can demonstrate their vessels/tanks comply with RAGAGEP(s). Here it goes:
When it comes to EPA’s Risk Management Plan rule, the state of California made significant modifications to the RMP rule. Basically, California replaced the Risk Management and Prevention Program with the California Accidental Release Prevention (CalARP) Program on January 1, 1997. The CalARP Program is very similar to the EPA’s Risk Management Program with the
Here is the presentation that Jim Lay, P.E., from OSHA’s Office of Chemical Process Safety & Enforcement Initiatives did last week @ ASSE’s Annual Conference. He did this presentation the same day OSHA rolled out their new enforcement policies on chemical mixtures and RAGAGEP enforcement. The presentation covers RAGAGEP Background, Early recognition of RAGAGEP, RAGAGEP
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. Last week OSHA changed their position in how they will handle “mixtures” of those chemicals listed in
Pressure decay testing, monitoring a gauge for a pressure drop over a specified period, is unacceptable as a standalone leak test under ASME B31.3 because the code explicitly mandates a 100% visual examination of all joints and connections while the system is under test pressure. While a pressure decay test can indicate that a system
With OSHA’s change last week in how PSM applies to “mixtures” of HHCs I have received a number of questions about “partial pressure” and what impact it can have on whether my process is covered or not? EPA has been using “partial pressure” of 10 mm Hg for their mixture applicability rule since 1999, but
MEMORANDUM FOR: REGIONAL ADMINISTRATORS AND STATE PLAN DESIGNEES THROUGH: DOROTHY DOUGHERTYDeputy Assistant Secretary FROM: THOMAS GALASSI DirectorDirectorate of Enforcement Programs SUBJECT: Process Safety Management of Highly Hazardous Chemicalsand Covered Concentrations of Listed Appendix A Chemicals This memorandum revises OSHA’s enforcement policy on the concentration of a chemical that must be present in a process for
MEMORANDUM FOR: REGIONAL ADMINISTRATORS AND STATE PLAN DESIGNEES THROUGH: DOROTHY DOUGHERTYDeputy Assistant Secretary FROM: THOMAS GALASSI DirectorDirectorate of Enforcement Programs SUBJECT: RAGAGEP in Process Safety Management Enforcement This memorandum provides guidance on the enforcement of the Process Safety Management (PSM) Standard’s recognized and generally accepted good engineering practices (RAGAGEP) requirements, including how to interpret “shall”
Today the US Chemical Safety Board released a DRAFT report on a 2009 Explosion and Fire at a petroleum terminal facility. So far, the CSB has identified “Inadequate Management of Gasoline Storage Tank Overfill Hazard” as the root cause of this accident. I can still remember the 2005 Buncefield incident that very closely mirrors this
CLICK HERE (doc) for one of the Contractor Work Permit written program that I used during my time as a Safety Manager in the chemical industry. CLICK HERE (pdf) for the Work Permit
