Chemical Process Safety (PSM/RMP)

Emergency Response Program (ERP) requirements differ for PSM and RMP

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

Draft Report of the Interagency Working Group on Refinery Safety – Improving Public and Worker Safety at Oil Refineries

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

Preventive Hazard Evaluation for Process Safety (Massachusetts Office of Technical Assistance Advisory)

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

OSHA reaches settlement agreement with Food Company to protect workers from NH3

A large food company has signed a settlement agreement with OSHA to protect workers at five (5) of its facilities from the release of anhydrous ammonia (NH3) from refrigeration systems.  The agreement protects workers at Idaho, Arkansas, Missouri and Ohio facilities. It requires the company to implement controls to reduce hazards associated with the release

RAGAGEPs and “the numbers”

The use of Recognized and Generally Accepted Good Engineering Practices (RAGAGEPs) has become a common occurrence since OSHA’s Process Safety Management standard and EPA’s Risk Management Plan rule came out in the 1990’s  Some professionals have come to hate RAGAGEPs and wish for the good ole days when OSHA promulgated prescriptive standards like 1910.23; and

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