Recently EPA issued a Consent Decree in response to a company that had two (2) facilities inspected under the Risk Management Plan Rule (40 CFR Part 68). The document was much like the many others I have posted here; however, this agreement contained a lengthy audit plan that EPA and the company agreed to as…...
For the life of me, I can not figure out the aversion to doing MOCs. I am guessing that my experiences in Petrochem were not the norm, as we used our MOC process for just about everything under the sun. Heck even the QC group used our MOC process. We rarely questioned the value of…...
I found this latest Letter of Interpretation regarding PSM Battery Limits an interesting read. The scenario is VERY COMMON and I am so glad OSHA wrote this letter! OSHA reminds us that cylinders stored in the same fire area (e.g. a fire has no passive control(s) to prevent its spread) that ALL of the cylinders…...
The long-awaited update of the ANSI K61.1 “Requirements for the Storage and Handling of Anhydrous Ammonia” is published by the Compressed Gas Association. The new edition was published as the CGA 2.1-2014 edition. The new edition, which is number six in the history of the standard, is considered the recognized and generally accepted good engineering…...
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Those of you that visit SAFTENG often know that I love the FM Global Data Sheets! These data sheets are NOW FREE (and have been for a couple of years). They serve as a GREAT AID in helping facilities understand their hazards and risks associated with all kinds of industries. In fact, although my practice…...
The Department of Homeland Security (DHS) continues to strengthen security at the Nation’s high-risk chemical facilities through the Chemical Facility Anti-Terrorism Standards (CFATS) program. Chemical Security Program Statistics as of January 5, 2015: More than 48,000 preliminary assessments were reviewed by DHS from facilities with chemicals of interest 3,598 facilities are currently covered by CFATS…...
Question: How may a corporation with multiple facilities regulated under CFATS request the corporate approach and what benefits does this provide the corporation?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
A question I am asked nearly each month is… do I have to have a person dedicated to operating the boiler and is this person restricted from performing any other functions while acting as the “boiler operator”? While I am not a “boiler expert”, most of my clients have industrial size boilers associated with their…...
The U.S. Chemical Safety Board released a safety bulletin intended to inform industries that utilize anhydrous ammonia in bulk refrigeration operations on how to avoid a hazard referred to as hydraulic shock. The safety lessons were derived from an investigation into a 2010 anhydrous ammonia release. The accident occurred before 9:00 am on the morning…...
Yes. A facility closure may be considered a material modification to a covered facility. In this case, the facility must complete and submit a revised Top-Screen to the Department of Homeland Security (DHS) within 60 days of the material modification (i.e., its closure), in accordance with 6 C.F.R. § 27.210(d), available at http://www.ecfr.gov/cgi-bin/retrieveECFR?gp=&SID=5490ca42ba3517c7c9aec9c47cefc750&r=PART&n=6y1.0.1.1.11. When completing…...
2/4/2015 UPDATE After many lengthy discussions with engineers and inspectors I have come to the conclusion that although this practice may be permitted by code, albeit by a five-word phrase in an interpretation, most engineers stated they would NOT use a dual stamped vessel unless it was careful analyzed via a PHA or detailed engineering…...
