UPDATED 8/17/14 Routinely we hear the argument that Anhydrous Ammonia should not be on OSHA’s or EPA’s chemical lists for PSM/RMP inclusion. Like most industries that use a single highly hazardous chemical as a “utility” in their process(es) v.s. manufacturing the HHC or using the HHC in the manufacturing process, these industries feel “their chemical” […]
The White House, Office of the Press Secretary For Immediate Release August 01, 2013 EXECUTIVE ORDER – IMPROVING CHEMICAL FACILITY SAFETY AND SECURITY By the authority vested in me as President by the Constitution and the laws of the United States of America, it is hereby ordered as follows: Section 1. Purpose. Chemicals, and the facilities
A common situation we find is that facilities struggle to understand how their “initial start-up” procedure for a new piece of process equipment can/will differ from their other start-up procedures for the equipment (e.g. normal, after a turnaround, after an emergency shutdown, etc.). Recently I have learned of a process used on galvanized condenser coils/tubes that
There is one small little sentence in 1910.119 (as well as Part 68) that is causing all kinds of heartburn. I like to call this requirement the “General Duty Clause” of process safety. To fully understand what this requirement entails we first have to understand what is meant by a standard being a “performance oriented”
Although the RMP Prevention Plan requirements for Program 2 and 3 very much mirror OSHA’s PSM requirements, the emergency response program requirements found in 68.95 Emergency Response Program go above and beyond the requirements of 1910.119(n) Emergency planning and response. OSHA’s 1910.119(n) Emergency planning and response directs us to comply with 1910.38 and 1910.120. And although EPA enforces 1910.120
I recently had some conversations with fellow safety and fire professionals regarding scaffolding erected in their process units. There seemed to be a lot of scaffolding and very little activity on it, so I asked the question… is there a limit on the amount of surface area that can blanket process equipment to the point
A major explosion at the Chevron refinery in Richmond California in August 2012 resulted in no fatalities and led 15,000 people in the community to seek medical attention. That event spurred the Governor to establish a Task Force to examine what steps should be taken to improve refinery safety in the State. The RAND Corporation
In the aftermath of a serious chemical release and fire at Chevron’s Richmond oil refinery in August, 2012, the Brown Administration formed an Interagency Working Group to examine ways to improve public and worker safety through enhanced oversight of refineries, and to strengthen emergency preparedness in anticipation of any future incident. The Working Group consisted
You may be aksing why I posted this in the PSM/RMP Section; simple, all of the incidents in this alert occurred in a chemical processing area, even though they may have not been covered by PSM/RMP, they no less occurred in processing areas! In response to the findings from an NTSB investigation, PHMSA is issuing
The five most common violations of Risk Management Program in EPA Region 10 (WA, OR, ID, AK), regardless of chemical or industry, are:
The Massachusetts Fire Code hazardous material processing regulation (527 CMR 33) requires a hazard evaluation or limited process safety program for many companies that have never faced this requirement before, (though many companies have been essentially performing these tasks as good practice). Many companies covered by this regulation must now document that a hazard evaluation
MANY THANKS to John for sharing this with his group! John is now retired from OSHA but was Region V’s Assistant Regional Administrator for years. He is one fine safety professional! Nfpa Process Safety Management and OSHA 6 8 2013 from John Newquist
