Chemical Process Safety (PSM/RMP)

This notice is to inform you of an increase in the number of hazardous materials (HM) incidents involvingAnhydrous Ammonia (NH3) and Liquefied Petroleum Gas (LPG)

OSHA has clearly established that hotwork can not take place in the presence of combustible dusts. 1910.252(a)(2)(vi) Prohibited areas. Cutting or welding shall not be permitted in the following situations:

We continue to see facility’s struggling with the basics of hot work safety. Most of these businesses are self insured and therefore do not have the extra set of eyes from their insurance carrier from time to time. But all do have catastrophic insurance and I am amazed that these carriers do not expect more.

Today I spent the day helping a company, insurance investigator and fire marshal investigate a Hot Work (HW) fire at a facility. The facility swore up and down that they follow their hotwork procedures to the letter and that there is no way that hotwork could cause the fire. When it came my time to

That is PSM lingo for…when you are utilizing Risk Based Inspection (RBI) protocols and you wish to extend the inspection or PM frequencies on a piece of covered equipment, this is without a doubt a change that REQUIRES an MOC.

Following the Buncefield incident the importance of preventing loss of containment from bulk storage tanks has come to the fore. A significant factor in ensuring contained fluids are not accidentally released is the continuing mechanical integrity of the tank structure. http://www.hse.gov.uk/research/rrhtm/rr760.htm

OK, PSM requires us to evaluate our “contractors” who will be working on, in or adjacent to a covered process. OSHA’s Permit Required Confined Space Standard also comes into play during a PSM audit (see .119(f)(4)). Under the PRCS std. OSHA requires us to “evaluate” our rescue services (.146(k)(1)(i)-(ii)) using something similar to Appendix F

We always get the answer…”We do not have any temporary operations,” so that does not apply to us. A good auditor will educate the site personnel by taking them out to the field and finding a bypass around a control device. Then, we will ask for the “procedure” that is used when the bypass is

Often we see facilities viewing MOC and PSSR’s management systems as DUPLICATIVE efforts. There is a distinct difference between these two PSM/RMP requirements. Basically, this is how it was so explained to me by Russ Evanston, one of the founding fathers of PSM.

OSHA and EPA are now citing for not doing MOCs on personnel changes!  The debate rages on for those living in the PSM/RMP world. Just this week, a client called me to help them with an audit finding they received in a third-party audit. The auditor wrote the finding that they were not considering personnel

“Recognized And Generally Accepted Good Engineering Practice” (RAGAGEP) – are engineering, operation, or maintenance activities based on established codes, standards, published technical reports or recommended practices (RP) or a similar document. RAGAGEPs detail generally approved ways to perform specific engineering, inspection or mechanical integrity activities, such as fabricating a vessel, inspecting a storage tank, or

A lot of PSM/RMP covered processes utilize ventialtion as an engineering control within the process.  And if this is the case, then OSHA and EPA require the facility to have supporting documentation to show that the ventilation will do what it it intended to do.