The critical issue is that a proposed change’s direct and indirect effects on the control of hazards should be identified and assessed. Due to the greater potential consequences of an accident, major accident hazard sites should aim for greater reliability in their planning and decision-making. Avoid too many simultaneous changes, which may result in inadequate […]
The FMCSA has begun Phase III of a project to refine the non-destructive metallurgical testing method and protocol for detecting cracks in nurse tanks and to determine possible relationships to causal factors not previously considered in detail. Background:
A client recently underwent an RMP inspection by the US EPA. One of the issues the inspector took issue with was that the facility did not “certify” their 3-year audit. This stems from the following: (emphasis by me) EPA RMP § 68.79 Compliance audits(a) The owner or operator shall CERTIFY that they have evaluated compliance
It is 2024, 32 years after OSHA passed its Process Safety Management of Hazardous Chemicals standard. I am fortunate to have clients who have progressed in their PSM maturity, and we spend a lot of time these days working to get other processes into the PSMS. We start with processes that are not covered because
This rulemaking requires the Air Conservation Commission to develop a state rule and accept delegation from the EPA. This rulemaking will lay the groundwork for the Agricultural Anhydrous Ammonia RMP Compliance and Enforcement program. Once delegated, the oversight for the RMP program will transfer from EPA to DNR. The benefit of this rulemaking affects the
The Occupational Safety and Health Administration (OSHA) issued a Request for Information (RFI) on December 9, 2013 (78 FR 73756). The RFI identified issues related tomodernization of the Process Safety Management standard and related standards necessary to meet the goal of preventing major chemical accidents. OSHA completed SBREFA in August 2016. OSHA held a stakeholder
All changes to an organizational structure or changes in personnel with specific Knowledge, Skills, Experience, and Behaviors (KSEB) must be assessed to understand the impact of the organizational change on safety. Any organizational change has the potential to introduce safety hazards and risks, and therefore, all changes to an organizational structure or changes in personnel
The systematic process to manage any change should follow the “Plan, Do, Check, Act” approach. This should start at the planning stage BEFORE: the change has been fully developed, continued and monitored during the change process and reviewed after it has been implemented. This systematic approach applied to all changes to equipment, infrastructure, policy, or
How much time does the owner or operator of a stationary source have to submit a correction to a Risk Management Plan when the emergency contact information changes?
On May 6, 2021, the Environmental Protection Agency (EPA) published a Final Rule listing R‒452B, R‒454A, R‒454B, R‒454C, and R‒457A as acceptable substitutes, subject to use conditions, for use in residential and light commercial air conditioning and heat pumps. These refrigerants are flammable and are classified as belonging to ANSI/ASHRAE Standard 34 safety group A2L.
A few weeks ago, I gave a sneak peek at what was coming: Manufacturer’s Limitations of Sulphur Sticks. Today, it arrived in the form of an OSHA LOI. A sulfur stick is a tool used to find ammonia gas leaks. Sulfur sticks, when burned, react with ammonia gas to make a visible smoke and are
Does all fixed/portable/mobile equipment that is installed or enters a Hazardous Location (HAZLOC) have to be “certified” and “labeled” as being acceptable for that specific HAZLOC? The blunt answer is YES! But in today’s working world and global economy, I am seeing a lot of foreign approvals for electrical equipment that is not by one
