As we continue to “dumb down” RAGAGEPs to take away OSHA/EPA’s ability to cite fundamental engineering failures found in processes handling HHC/EHS, the issue of “conflicting requirements” continues to be troubling. As my Anhydrous Ammonia clients learned firsthand last year, with the 7th edition of CGA 2.1, the RAGAGEP has some NEW requirements for pressure […]
Both OSHA and EPA require PSM/RMP facilities to include procedures for “responding to small releases” in their Emergency Action Plans 1910.119(n) Emergency planning and response The employer shall establish and implement an emergency action plan for the entire plant in accordance with the provisions of 29 CFR 1910.38. In addition, the emergency action plan shall
A loss of containment and subsequent release of fluids can cause adverse consequences (i.e., impact safety, health, and environment, cause production losses, andincur maintenance and reconstruction costs). The risk analysis should consider the nature of the hazards and ensure that appropriate factors are considered for the equipment items being assessed. Flammable Events (Fire and Explosion)
29 CFR 1910.119(f)(1) The employer shall develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information.
In process safety circles, the word “remote” is found in several codes/standards. In OSHA’s Process Safety Management standard, we find it used in the Normally Unoccupied and Remote Facility (NURF) exemption (1910.119(a)(2)(iii). OSHA did us a favor by officially defining this phrase; however, they have never QUANTIFIED it. Normally unoccupied remote facility means a facility
On May 23, 2023, @ 9:00 a.m. Employee #1 and Employee #2, both maintenance workers for a petroleum refinery, were troubleshooting an automated valve in the “Prime G Unit.” Flammable gasoline/hydrocarbons in the piping and flange portion of the automated valve were released, causing an explosion, and fire.
The word “adjacent” may be small in terms of letters used to spell it, but it has an enormous impact on the world of process safety. Both OSHA’s Process Safety Standard (1910.119) and EPA’s Risk Management Plan (Part 68) use the word “adjacent.” Here is how Webster defines “adjacent” adjacent (adjective): not distant: nearby It
A great and reliable resource to help comply with… 1910.119(f)(1)(iii)(C) Control measures to be taken if physical contact or airborne exposure occurs; https://www.cdc.gov/chemicalemergencies/factsheets/ammonia.html
This week, OSHA posted an LOI regarding terms used in the PSM Standard, and this LOI has generated some discussions amongst some SAFTENG members, most notably… How are we required to document our HAZLOCs? In OSHA’s LOI, it referenced 1910.307 Hazardous Locations standard which simply states: (emphasis by me) 1910.307(b) Documentation All areas designated as
On June 18, 2021, at 6:30 p.m. an employee was working for a firm that operated electric power generation facilities. He was working at a natural gas-fired power plant. He and a coworker were restoring a natural gas filter system at the power plant by aligning valves after a maintenance crew had replaced filter media.
At 9:20 a.m. on July 12, 2023, an employee working as a supervisor was testing for leaks in a tank at a leak test station. Tanks are laid on their side for leak tests. The top of the tank faced the pressure test chamber, and the bottom faced the opposite direction. The employee began grinding
Not only did OSHA update its Compliance Directive for Process Safety Management standard 1910.119, effective January 26, 2024, this week, they also posted a Letter of Interpretation (LOI) clarifying several key terms used in its PSM Standard. Terms defined include: Employer Employee Access, as used in the EP element Accessible, as used in the SOP
