This is not the first time I have “beat up” on excess flow valves and the reliance on them as a “safeguard” in a PHA or process design. Both EPA and OSHA are on record stating their displeasure of claiming these valves as a safeguard. Now don’t get me wrong, these devices WORK and WORK […]
Christine Baker, Director of the Department of Industrial Relations (DIR), has submitted a legislatively-mandated status report on DIR and Cal/OSHA’s Process Safety Management (PSM) Regulatory Oversight. The report is required pursuant to the Budget Act of 2014 (Provisions 1 and 2 of item 7350-001-3121, Chapter 25, Statutes of 2014). A new assessment on the state’s
I am working on getting all of these RMP NOVs posted but found this one especially interesting… XXXXXXXXXX did not address the impact of the lock-out of the factory workers in August 2011 and hiring all new replacement workers. Such extensive staffing changes could impact the safety and health of the XXXXX workers and should
A Pressure Vessel subject to Internal Corrosion shall be defined as any metal Pressure Vessel using a processed product that can cause Corrosion, Erosion, Pitting, Cracking, or Deterioration, as defined in Part 2, 3.3 of the National Board Inspection Code. The intent is to verify the vessel is safe to operate. Pressure Vessels subject to
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 March 2, 2015: More than 48,000 preliminary assessments were reviewed by DHS from facilities with chemicals of interest 3,471 facilities are currently covered by CFATS
There are over 75 billion pounds of hazardous chemicals regulated under the RMP rule. Top Five (5) RMP Chemical Quantities
As I posted back in August 2014, CAL EPA was looking to make changes to the CALARP rule. The proposed petition process was rejected but the rest of the package was accepted and were approved by the Office of Administrative Law and took effect on January 1, 2015. The Governor’s Interagency Task Force on Refineries has suggested additional amendments
This is an interesting turn of events! The ALJ upholds most of the citations and then OSHRC vacates them all. This after a 750-pound release of butylene oxide that occurred during a line break activity and was caused by an IMPROPER energy control plan. One worker was diagnosed with “chemical pneumonia” due to his exposure to the
The purpose of this letter is to make Agricultural Anhydrous Ammonia handlers in Iowa aware of new Anhydrous Ammonia Standards and changes the adaptation of the new standards and exceptions may bring. On December 15, 2014, CGA (Compressed Gas Association) received a Notification of Final Action on ANSI/CGA G-2.1, 2014, Safety Requirements for the Storage
Not a trick question but boy do we get “the look” when we ask the question just as it is written in 68.79 and .119(o). What do OSHA and EPA mean by certifying an audit? Who does this certification? Is this a formal exercise of certifying? Why did OSHA/EPA use this term in the standard?
I recently participated in a PHA for a large flammable liquids process and during the “facility siting” portion of the PHA we took a detailed tour of the process. During which, several significant “impact” hazards were identified. Of course, the long-time engineering manager (40 plus years of fine service at the facility) quickly went to the
