OSHA PSM Process Hazard Analysis Citations in 2022
In OSHA’s fiscal year 2022, Process Hazard Analysis was the #4 most cited element of the PSM standard. Here is a breakdown of those citations…
OSHA PSM Process Safety Information Citations in 2022
In OSHA’s fiscal year 2022, Process Safety Information, was the #3 most cited element of the PSM standard. Here is a breakdown of those citations…
OSHA PSM Mechanical Integrity Citations in 2022
In OSHA’s fiscal year 2022, Mechanical Integrity (MI), was the #2 most cited element of the PSM standard. Here is a breakdown of those citations…
SOPs over take MI in OSHA’s 2022 PSM citations
OSHA’s fiscal year 2022 saw a significant change in the leading PSM element for citations. As far as I know, Mechanical Integrity has been the most cited element every year for the past 20 years. And it held that spot convincingly for those years. Last year, SOPs took the top spot with…
Detailed breakdown of PSM inspection data for 2022
In my earlier post, my data showed OSHA conducted 66 PSM inspections and issued 347 citations. Now that I have all the data in raw form, I saw 430 citations in 2022. The discrepancy is likely due to one database using the “issuance date” and the other using the “final order” date. And yes,
CFATS by the numbers on its 15th Anniversary
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…
EPA offers insights into “Responding Facility” vs. “Non-Responding Facility”
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
EPA RMP triggers to have your case referred to DOJ
Here are the six (6) triggers that will get your RMP Inspection Case referred to DOJ:
Electric sweet gas heater ruptures and releases sweet gas into the building
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
CSB calls on OSHA to develop guidance documents for performing PHAs on SOPs
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
Connecting a Compressed Gas Cylinder to a “process”
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
Line Break gone bad (Chlorine Dioxide)
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.