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.
No hunman and no organization is perfect! Although we should strive for perfection in all aspects of business (Production, Quality, Cost Control, and EHS), we often mis-step or possible loose our way altogether. But how bad do things have to get before it is a REAL PROBLEM?
I continue to see facilities struggle with the emergency shutdown SOP requirements and how it is all suppose to flow and fit into the daily operations. In this post I will try and lay out a flow to help make sense of these PSM/RMP requirements. I am hopeful you can learn from my mistakes, as
We do not see these types of failures often, but when we do, it can almost always be traced back to human error. Back in 2008, a tube-and-shell heat exchanger catastrophically failed when workers accidentally closed two different valves at two different times between the vessel and its relief valve. On June 10, 2008, operators
Does the title make you scratch your head? I usually get some strange looks when working with a client who is trying to understand what the PSM compliance cycle looks like. To start with, let’s look at what OSHA/EPA requires in our operating procedures: 1910.119(f)(1)(ii) Operating limits 1910.119(f)(1)(ii)(A) Consequences of deviation 1910.119(f)(1)(ii)(B) Steps required to
If your PSM/RMP covered process contains a flammable liquid, 1910.106 has provided us with some regulatory facility siting requirements that we can quickly inspect to ensure we meet the minimum compliance distances. If you have liquefied petroleum gases within your facility, 1910.110 provides some basic siting requirements that should be met to have an argument
Many chemical processes that are covered under OSHA’s PSM and EPA RMP rules utilize one of the most popular forms of passive mitigation ever known…Diking. However, on the other hand, many of the facilities have not included their dikes in their Process Safety Information (PSI) or their Mechanical Integrity Programs (MIP).
I had an interesting dissertation given to me on how to calculate “frequency” when analyzing a PHA scenario during a recent PHA. Although it sounded logical, it was completely off base and thus would have shown the facility at very low risk for all their scenarios. This is something we see from time to time
