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…...
A Step Change in a facility’s Process Safety Management System Read More »
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 State of Missouri seeks to be the “delegated enforcement authority” for NH3 RMPs Read More »
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…...
OSHA’s progress in revising the PSM Standard Read More »
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…...
Managing Organizational Changes Read More »
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…...
Managing Changes using the “Plan, Do, Check, Act” management system approach Read More »
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?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
Time Frame to Submit RMP Emergency Contact Information Changes Read More »
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…...
The use of a sulfur stick (NH3 leak detection) is hot work (1910.119(k) LOI) Read More »
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…...
As I have said for years, we may never know where the nasty rumor came from that installing threaded and/or flanged piping is easier and cheaper than welded pipe. That is a “pipe dream”… LOL see what I did there? For example, did you know that if the piping will be pneumatically pressure tested, then…...
One of the significant deficiencies we find in our audits/investigations is the lack of meeting ASME B31.3/.5 to install process piping. I have written about this topic for decades, and I still get inquiries monthly about this standard and its critical role in real process safety management. For those who attend my 5-day Advanced PS…...
How many welds must be visually inspected and/or tested? (ASME B31.3) Read More »
Those of you who practice in the Process Safety arena are well aware of OSHA’s and EPA’s requirements to have “written procedures to maintain the on-going integrity of process equipment.” (1910.119(j)(2). However, OSHA and EPA also have a section in their Mechanical Integrity elements titled “Quality Assurance.” 1910.119(j)(6) Quality assurance. 1910.119(j)(6)(i) In the construction of…...
Written Procedures for the QA of “Piping/Weld Examinations” (1910.119(j)(6) Read More »
