Chemical Process Safety (PSM/RMP)

OSHA issues Facility Siting citation under 5(a)(1) rather than PSM

NOTE: these are from the fatal 2014 NH3 Truck Unloading accident, where the “bleed tank” (which was a plastic IBC) catastrophically failed because a liquid NH3 valve was left open. I have no idea why this 5(a)(1) was not issued as a RAGAGEP citation using ANSI K61/CGA 2.1, which is where the facility siting requirements

Chemical Accident Risk Reduction NECI Goal FY 2024 RESULTS (NH3 and HF)

Launched in 2017, this Chemical Accident Risk Reduction National Enforcement and Compliance Initiative (NECI) seeks to reduce risks to human health and the environment by decreasing the likelihood of chemical accidents. This will be achieved by addressing significant noncompliance with the general duty to maintain a safe environment and risk management plan rules. Given the

What does an RMP $10M SEP look like?

The SEP will provide the emergency response equipment to the identified emergency response organizations to assist them in responding to emergencies in the communities where the Covered Refineries operate and where chemical processes are undertaken that the CAA regulates. XXXXX is obligated to expend Ten Million Dollars ($10,000,000), which includes all administrative costs associated with

What constitutes “significant property damage on site?”

Under the hazard assessment requirements at 40 CFR Part 68, Subpart B, the owner or operator of a covered stationary source must document a five-year accident history that includes all accidental releases from covered processes that resulted in deaths, injuries, or significant property damage on site, or known offsite deaths injuries, evacuations, sheltering in place,

Are chemicals in a tank car exempt from threshold determinations under 40 CFR Part 68 (RMP)?

Back to an old question that continues to be asked… Are chemicals in a tank car exempt from threshold determinations under 40 CFR Part 68 (RMP)? The definition of stationary source does not apply to transportation, including storage incident to transportation (40 CFR Section 68.3).  Are chemicals in a tank car (e.g., tanker truck or

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