Chemical Process Safety (PSM/RMP)

PLEASE NOTE this case is significant in that many facilities in the OSHA arena will EXEMPT their “methanol” from PSM coverage using the “Atmospheric Storage Tank” exemption (e.g. 1910.119(a)(1)(ii)(B) or called the “Meer Decision”).  EPA couldn’t care less about this OSHA exemption, as is evident in this case! There is NO EPA RMP exemption for flammable liquids stored…...

The objective of this project was to conduct refrigerant R-290 (propane) leak and ignition testing under whole room-scale conditions to develop data and insight into the risks associated with the use of Class A3 Refrigerants and to generate technical data to support revisions of relevant safety standards.       The entire project included parametric testing…...

  P1 P2 P3 Third-party audits (applies to the next scheduled audit after an accident)   √ √ Incident Root Cause Analysis (only for facilities with accidents/near misses)    √ √ Safer Technologies Alternatives Analysis (STAA) (applies to a subset of P3’s in certain NAICS codes)      √ Coordinating Emergency Response Program Requirements with…...

One of the more common misses by a lot of businesses, especially those using pressure vessels (PVs) in their PSM/RMP covered processes, is the “initial inspection” at the time of installation.  We have discussed the “change of service” inspection several times; however, this inspection is for NEW PVs being installed.  This requirement will certainly apply…...

EPA recently announced its enforcement and compliance assurance priorities for fiscal years 2020 to 2023. There are seven (7) priority areas in total for this period, six of which are National Compliance Initiatives (NCIs), which will be led by EPA’s Office of Enforcement and Compliance Assurance.  The one that I follow closely is…… Membership Required...

In the recent OSHRC decision where the ALJ decided that “tight-fitting” doors for an engine room/machinery room doors were not a PSM requirement since “doors” were not part of the covered process. What is confusing is that the company successfully convinced the ALJ that ASHRAE 15 was not their chosen RAGAGEP (even though they stated…...