Betting this was just under 10 pounds. That’s a RQ joke as the RQ for Cl2 is 10 pounds – CLEARLY we have exceeded that in this event. (But you never know!) All jokes aside, this is a big one. People wanting to know why it’s taking so long to get an “all clear” 2-hrs […]
The PSM standard requires the employer’s PHA team to evaluate human factors during its process hazard analysis. CCPS defines human factors as “a common term given to the widely-recognized discipline of addressing interactions in the work environment between people, a facility, and its management systems.” The basic principle of assessing human factors is to determine
The Management of Change (MOC) section of the PSM standard requires the employer to implement written procedures for managing changes (except for replacements in kind) to processes involving chemicals, technology, equipment, procedures, and changes to facilities that affect a covered process. The MOC procedure requires descriptions of the technical basis for the change, impact on
OSHA has identified the following mistakes found at PSM facilities nationwide. These mistakes were identified at refineries; however, almost all can be found within any PSM-covered process. I have revised OSHA’s wording so that we can ALL learn from these mistakes. PLEASE do not fall for the old trap of “Bryan, we are not a
The risk management program in 40 CFR Part 68 requires facilities to conduct an off-site consequence analysis (OCA) to provide information to state, local, and federal governments and the public about the potential consequences of an accidental chemical release. When does a facility need to revise its OCA?
When using RMP*Comp to conduct an offsite consequence analysis (OCA), a facility must specify the quantity released. What quantity should be entered for a regulated toxic substance in an aqueous solution, the total quantity of the aqueous solution or just the quantity of the toxic substance?
The definition of public receptor is “offsite residences, institutions (e.g., schools, hospitals), industrial, commercial, and office buildings, parks, or recreational areas inhabited or occupied by the public at any time without restriction by the stationary source …” Offsite is further defined to include “areas within the property boundary [of the stationary source] to which the
When analyzing the worst-case scenario for regulated toxic substances, must I anticipate a specific cause (e.g., fire, explosion, etc.) of the scenario?
Does public receptor cover only buildings on a property or the entire property? If the owner of the land next to my site restricts access to the land, is it still a public receptor?
What if a flammable event has a different time duration than the 5 kw/m2 for 40 seconds?
For the worst-case and alternative release scenarios of an underground storage tank, should I consider any impact on groundwater, drinking water, or soil?
I am working on the five-year accident history portion of the hazard assessment under the RMP. Section 68.42(a) tells me to include “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, property damage, or environmental damage.” Is there
