As I have discussed many times with many clients, the practice of “bench testing” relief valves (RV) is a common practice in many industries; but in some industries, the practice has been considered to be a waste of time and money. At least that was the case until now! It appears that one major trade […]
Here is a nice presentation the California Interagency Refinery Task Force did in June 2015: CAL-OSHA has issued an NPRM for a REVISED PSM Standard. In addition to proposing changes to existing PSM language, the draft proposal introduces new requirements in the following areas: damage mechanism reviews hierarchy of hazard controls analysis human factors management of organizational
Yes, as many of you have figured out I am a big fan of using the Management of Change process to actually manage changes that may officially be outside the PSM/RMP requirements. But how OSHA changing their injury/illness reporting requirements impact my Process Safety Management System? Here’s how…
Not meant to be a trick question, but the matter of workers who MUST wear medically prescribed devices and work in Class I, II, and/or III Hazardous Locations tends to be a constant question for facilities that have HAZLOCs. Low voltage equipment is always a battle in HAZLOC! I swear the engineering schools in this
On March 20th, 1989, the pressure in the cryo tank climbed abruptly between 11:00 a.m. and 11:15 and the tank burst at its base. Under the effect of the wave escaping from the gaping breach, the reservoir broke free from its stand, pushed in the opposite direction. It destroyed the reinforced concrete protecting wall and
This summer we saw a 300,000-gallon water tank fail which pushed a generator into a covered process which led to a release of the HHC/EHS. The questions I wish to pose are: Should the water tank have fallen under the PSM/RMP program due to its proximity to the covered process? Should the proximity of the
The 2014 proposed CalARP regulations have been submitted to the Office of Administrative Law. Some of the proposed changes/revisions to the rule are quite helpful in many aspects and some will be significant hardships. Here are some of the more significant ones I noticed:
A CFATS Authorization Inspection (AI) is conducted at covered facilities to verify and validate that the content listed in the facility’s authorized Site Security Plan (SSP) or Alternative Security Program (ASP) is accurate and complete and that existing and planned equipment, processes, and procedures are appropriate and sufficient to meet the established Risk-Based Performance Standards
Section 550 of the Department of Homeland Security Appropriations Act of 2007 authorized the Department to regulate the security of chemical facilities that, in the discretion of the Secretary, present high levels of security risk. Under the Section 550 authority, on April 9, 2007, DHS issued the CFATS interim final rule, codified at 6 CFR
On the most basic level, can a PSM/RMP program function and comply with all regulatory requirements and NOT have a calibrated direct-reading instrument? This is not meant to be a trick question, but rather looking to “ground me” in my expectations. Having grown up in the PSM/RMP era in petrochem for 20 years, having a
Last week I shared an article from allgov.com that provided some data on Ammonia releases. The article was not well received by some folks and others appreciated the info, which is par for the course when you post this kind of material. But some have gone off the deep-end and called the article “spin” and
