Chemical Process Safety (PSM/RMP)

I can still remember the day I was told: “the pipe failed its thickness testing – but don’t worry we are going to use a pipe clamp so we can keep using it”.  I had just attended my API 570 and 510 courses to learn all about process equipment inspection protocols.  Not once did I…...

We have yet another failure of enormous proportions.  When two workers, one of which is a Supervisor, are opening a liquid chlorine line and they have on supplied-air respirators without the regulator attached to the facepiece we have entered into the Twilight Zone.   WorksafeBC has levied a $318,707 fine against the city’s water-treatment plant for:…...

Whether we’re in process safety or just good ole fashioned occupational safety and health, the act of performing hot work (welding to the layperson – my feeble attempt at some Dumb and Dumber humor) can be one of the most dangerous task workers can perform.  Add in the fact the hot work is done within…...

Here is an initial look at the rule, signed by the CSB Interim Executive today. The final rule requires an owner or operator of a stationary source to submit an accidental release report to the CSB. The rule describes when to file a report of an accidental release and the required content of such a…...

The Risk Management Program (RMP) regulations require the owner or operator of a stationary source to revise and update the source’s RMP at least once every five years from the date of its initial submission or most recent full update (§68.190(b)).  Is there a procedure for obtaining an extension to complete the five-year review? … Membership...

The Risk Management Program emergency response coordination activities require the owner and operator of a stationary source to provide to the local emergency planning and response organizations: the stationary source’s emergency response plan if one exists; emergency action plan; updated emergency contact information; and any other information that local emergency planning and response organizations identify…...

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? The Risk Management Plan (RMP) regulations require an owner or operator of a stationary source to correct their RMP within one month (i.e., 30 days) of any…...

The following is a list of key safety measures developed by EPA in coordination with the International Institute of Ammonia Refrigeration (IIAR). They are measures that EPA and IIAR agree are required elements for ammonia refrigeration facilities (regardless of an ammonia refrigeration system’s age or size) for the system to meet the requirements of 40…...

During stakeholder outreach as part of EO 13650 and during OSHA’s PSM SBREFA (Small Business Regulatory Enforcement Fairness Act), OSHA and EPA received multiple comments from stakeholders expressing confusion on the applicability and overlap between OSHA’s Process Safety Management (PSM) standard and EPA’s Risk Management Plan (RMP) regulation. In the Clean Air Act Amendments of…...