November 20, 2022 was the anniversary of Chemical Facility Anti-Terrorism Standards (CFATS) regulations. And although it is not as well known as OSHA’s PSM and EPA’s RMP standards, it is a standard that many PSM/RMP practitioners deal with, so I thought it would be fitting to look at the CFATS numbers…
In a recent training course, the EPA answered the “One Big Question”… (one that I have written about many times) Does the facility rely on emergency responders to stop the release of the regulated substance(s)? If the facility answers Yes, they are saying the local first responders will respond and stop the release. This means
Here are the six (6) triggers that will get your RMP Inspection Case referred to DOJ:
This incident was process related and involved a process safety system; however, the process was NOT PSM/RMP covered. The incident is process-related and many of the PSM/RMP management elements could have prevented this incident. An electric sweet gas heater ruptured from overheating releasing sweet gas into the building. The cause of the incident was likely
In the CSB’s final report on a refinery incident, the agency calls on OSHA to: Develop guidance documents for performing process hazard analysis on operating procedures to address transient operation hazards in facilities with Process Safety Management (PSM) covered processes. A PHA is a critical element of the process safety management system; unfortunately, we see
It is pretty standard practice to hook up a compressed gas cylinder to a process. In fact, many “blanket systems” on a small vessel will use a Nitrogen CG cylinder to provide the blanketing gas. However, it is even more common to find this setup done improperly. In this article, I will offer a RAGAGEP
On June 27, 2022, an employee was flushing a chlorine dioxide pump for maintenance. He inhaled the chlorine dioxide when it escaped. The employee was rushed to the hospital and later died.
For several editions, the IFC has incorporated a “Performance-Based Design Alternative” to comply with the requirements of Part V—Hazardous Materials (Chapters 50-67). This was initially added so that facilities already doing PSM/RMP could show compliance with the state fire code without any additional work. In the 2021 edition of the IFC, this alternative has been
In FY 2022, the agency continued its efforts to reduce risks of accidental releases at industrial and chemical facilities, such as: Concluded three (3) judicial actions, 145 administrative penalty actions, and 18 administrative compliance orders In FY 2022, EPA renewed its presence in the field and increased its on-site inspections by more than 150% compared to
OSHA’s VPP efforts in process safety has offered the following questions regarding the PSM activities in the process. Here are seven questions that will help you gauge your level of PSM expectations related to ammonia refrigeration:
Mr. Trevor Kletz is, without a doubt, my favorite author. In 2001 he published his book on Human Factors in process safety – “An engineer’s view of human error” (Third edition). It is a MUST-READ for those who practice process safety, significantly if you facilitate process hazard(s) analysis (PHA), including the Human Factors analysis. His
Over the last several years, OSHA has asked, in the annual Supplement B questionnaire, specific questions designed to help share information about the site’s safety and health management systems (SHMS), but mainly about the critical areas of PSM programs and established procedures used to maintain, collect, and analyze PSM systems/process metrics. In 2016, OSHA developed
