Inspect at least 4% of the total number of RMP-regulated facilities during FY 2014. Of these inspections, at least 36% should be conducted at high-risk RMP facilities, using the list derived from established high-risk criteria and provided by headquarters to regional offices at the beginning of the fiscal year. Regional program managers may, after consultation…...
The Risk Management Program (RMP) is implemented by the Office of Emergency Management (OEM) in EPA’s Office of Solid Waste and Emergency Response (OSWER). EPA and state and local implementing agencies conduct inspections at RMP facilities to determine compliance with RMP regulatory requirements, but because resources for conducting inspections are limited, within the past…...
This is an EXCELLENT presentation from EPA (4/2013) on doing RMP Inspections @ Ethanol Facilities. Although the presentation appears to be specifically for Ethanol facilities, it’s “suggestions and tips” WILL apply to any RMP covered facility (and for PSM-covered facilities as well). Some of the interesting revelations are: 1) EPA uses Google and Bing Satellite…...
This is why I have oh little faith in our government to protect us!!! Enforcement can NOT and should NOT be the driver behind improved environmental, health and safety performance! The hypocrisy in this report, aimed at the agency tasked with enforcing the very rule they wrote is nothing short of pathetic. Sitting here I…...
Does your process have any “underground piping”? We do not see this design in newer process designs, but in years past – putting pipe underground seemed like a good idea. This NTSB report does an excellent job of breaking down the failure modes of underground piping. The National Transportation Safety Board determined that the probable…...
Sizing emergency venting for atmospheric flammable liquid storage tanks is a safety-critical requirement, yet we often find it undersized. The core objective is to provide sufficient relief capacity so that, in the event of an external “exposure fire,” the tank does not rupture due to rapid internal pressure buildup from vaporizing liquid. Unlike normal venting…...
In June I will be presenting with my good friend and safety colleague Jonathan Zimmerman at the ASSE Conference in FL. Our presentation is “Process Safety Management Best Practices, Lessons Learned and Enforcement Trend”. Here is a peak at some very interesting data regarding PSM inspections from May 26, 1992 – February 26, 2014. Stop by…...
The following has been updated to resolve erroneous or incomplete data with reference to Category 2 and 3 Information and expanded resources for Category 1 compliance. This memorandum replaces the November 1, 2013, memo on the same topic. DFS apologizes for any confusion on the matter. We have passed the final deadline for permits to…...
Before OSHA reports are cleared and posted to its database, each summary undergoes a thorough investigation, revision, and screening process by OSHA, which can delay posting up to 5 years. For those reasons, the National Board has elected to research summaries that are greater than five years old. National Board began with years 2002-2007, and…...
It seems these days that having a relief valve header is the way to go; but why is that? Why are so many businesses deciding an “RV header” is the way to go with their RV Design Basis? In the process safety world, a facility is required to have a “relief design basis” and the…...
As I have mentioned before, this “temporary operations” mode confuses a lot of facilities. Almost all facilities will state, without hesitation, that they have no “temporary operations.” And almost always, as we proceed with our assessment/analysis, we find numerous “temporary operations.” As I write this posting, it is -10°F here in Cincinnati, OH, a temperature…...
After more than 18 months of working with communities, workers and industry leaders, the state’s Interagency Working Group on Refinery Safety (Working Group) today released its final report outlining recommendations to improve public and worker safety at and near the state’s oil refineries. A task force has already begun overseeing implementation of many recommendations and…...
