Today OSHA issued another REVISED POSITION in their enforcement of the Process Safety Management Standard. Today they rescinded their previous position and now employer(s) with employee(s) exposed to PSM-covered processes formerly exempted under OSHA’s 1992 interpretation of “retail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 National Board Annual Violation Tracking Report identifies specific violations (per device type) commonly found on five (5) types of pressure equipment during jurisdiction-required inspections. The following data reflects the reporting period of 1/1/2014 – 12/31/2014 as reported by participating member jurisdictions. The Violation Tracking Report indicates problem areas and trends related to boiler and
The National Board of Boiler and Pressure Vessel Inspectors has released its First 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 for
Yes, absolutely. A BLEVE is not restricted to materials that are gases at standard temperature and pressure (STP), such as propane, butane, or anhydrous ammonia. Any liquid—even non-flammable ones like water, as seen in catastrophic boiler explosions—can BLEVE if the right thermodynamic conditions are met prior to vessel failure.
A recent fatality at an ammonia refrigeration process in Canada points to a potential weakness in “contractor safety” at facilities with active process safety management systems in place. PSM/RMP facilities regularly get “safety information and data” from their contractors; this information is usually the contractor’s OSHA injury/illness rates, experience modification rate, etc. But many PSM/RMP
A fire at the Chevron refinery in Richmond in August 2012 raised public concern about refinery safety and emergency response in California. Following a directive from the Governor’s February 2014 report on “Improving Public and Worker Safety at Oil Refineries,” CalEPA formed the Interagency Refinery Task Force (IRTF). The IRTF membership includes ten state agencies,
Between 1996 and 2008 it is estimated that there have been 173 loss of primary containment (LOPC) incidents reported in RIDDOR that can be attributable to ageing plant. This represents 5.5% of all loss of containment events. The limited information provided in RIDDOR about the underlying causes means that it is difficult to identify which
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
