Chemical Process Safety (PSM/RMP)

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?

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.

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.

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

“The Natural Gas facility lacked a formal PSV testing procedure that included a QA/QC process to ensure that PSV’s are properly returned to service after testing with isolation valves car–sealed in their correct positions. At the time of the Incident, operators were trained to assist with PSV testing by observing another more experienced operator and

Preliminary investigation indicates that two (2) HVAC contractors were in the vicinity of the ammonia leak when it was initiated. Norwood’s first responders were able to stabilize and transport one man to Good Samaritan Medical Center, and he was then further transferred to Massachusetts General Hospital for specialized treatment.  The second contractor, 68, was deceased

I have written numerous times about how the PSM/RMP thresholds are inconsequential regarding line/vessel opening hazards.  A 1/2″ line in a water treatment process, NOT covered by PSM/RMP as it ran on 150# cylinders, poses the same risks as if the 1/2″ line was part of a covered process.  Granted, the LOPC event could release