Oleum, which is a mixture of sulfuric acid and sulfur trioxide, is listed as a regulated toxic substance in 40 CFR §68.130. Sulfur trioxide is also listed individually as a regulated toxic substance. Suppose a single process consists of one vessel containing oleum and one vessel containing sulfur trioxide. Must the amount of sulfur trioxide…...
Why are hydrochloric acid and hydrogen chloride listed separately in the list of regulated substances at 40 CFR §68.130?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
Several toxic substances are listed as regulated substances under 40 CFR §68.130 with concentration qualifiers (e.g., “conc 37% or greater”). What does this concentration mean? When determining whether a threshold amount of these substances exists in a process, should I consider the weight of the entire solution, or simply the amount of the regulated toxic…...
Drums containing regulated substances (listed in 40 CFR §68.130) are stored in several separate locations at a stationary source and there is no possibility that an accidental release in any of the individual storage areas would impact any of the other storage areas. Must the overall amount of the regulated substance present at the stationary…...
Under 40 CFR Part 68, to determine whether more than a threshold amount of a regulated substance is present at a stationary source, certain exemptions may apply. One such exemption is provided for “activities in laboratories” (40 CFR §68.115(b)(6)). If laboratory chemicals are stored outside the laboratory, are they exempt from threshold determination?… Membership Required...
Effective February 24, 2023, 6:00 p.m. EST, the registration process for RMP*eSubmit Certifying Officials is changing to use additional Central Data Exchange (CDX) registration features. Certifying Officials will now be required to identity proof and sign a standard CDX Electronic Signature Agreement (ESA) as part of CDX the registration process. The CDX ESA is different…...
I get about a dozen calls a year from folks asking me about their PSM/RMP due dates. I try to explain that of course OSHA or EPA can cite the facility if the audit is past due. For example, the last audit was done the 2nd week of February 2020, it is expected that the…...
This is from an EPA Multimedia inspection that looked at a chemical process that was below the TQ, so they used the RMP GDC to inspect. What they found in the flammable process was that… … several of the facility’s components were made of aluminum. One condenser was installed with malleable iron tubes instead of…...
Three (3) fundamentals are behind the “electrical classification” model for hazardous locations. These three fundamentals mirror our approach to other workplace hazards, and understanding these three fundamentals will help make a lot of sense out of NFPA 497/499 and 1910.307…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member?...
The US still uses the Class and Division system to classify electrical systems in hazardous locations. However, outside the US, the Zone system is more widely used. Manufacturers are beginning to list their equipment based on the Zone(s) it is rated for, which can cause translation confusion. The table below may be of help…. Membership...
Yesterday, OSHA announced its plans to promulgate a revised Process Safety Management (PSM) standard and a NEW Emergency Response Standard in 2023. Executive Order 12866 requires the semiannual publication of an agenda of regulations listing all the regulations the Department of Labor expects to have under active consideration for promulgation, proposal, or review during the…...
When writing SWPs/SOPs be sure how you phrase things. KNOW your audience. An elementary teacher got what she asked for when she simply asked the class to draw a clock showing the time as 10 minutes past 11. This exercise is called the Clock Drawing Test for Cognition. Usually reserved for the elderly or someone…...
