Chemical Process Safety (PSM/RMP)

How many times have you heard, or maybe you were the one saying it, that “our initial start-up is the same as normal start-up and that is why we do not have initial start-up procedures”? If I had a $20 bill each time we heard this I would be retired!!!!  Recently I was talking process […]

Question Under the Chemical Facility Anti-terrorism Standards (CFATS), should a regulated facility submit a revised Top-Screen if it changes either the type (i.e., bulk versus portable packages/containers) or the amount of Ammonium Nitrate (AN) that it possesses?

The first step to emergency preparedness is defining and analyzing hazards. Although all hazards should be addressed, resource limitations usually do not allow this to happen all at once. Risk assessments are used to establish priorities so that the most dangerous situations are addressed first and those least likely to occur and least likely to

OSHA, combined with our State Plan partners, has approximately 2,200 inspectors responsible for the health and safety of 130 million workers, employed at 8 million worksites around the nation.  Although workplace conditions today are much safer than when OSHA was created, over 4,300 workers are still killed in the workplace each year and millions are

This is a topic I have written about several times before and EPA has made their position fairly clear in their RMP Q&A’s.  SAFTENG members can CLICK HERE to read the summary of the EPA Q&A’s regarding railcars that are NOT attached to a mode of transport (i.e. locomotive).  These railcars that sit out on

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

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