In my discussions with SAFTENG members who are Process Safety clients, the question is always asked: “Where do you get the terms “responding facilities” and “Non-Responding facilities” from? These are terms used in EPA’s Risk Management Plan rule, and I have said many times in my writings that not every facility is required to have […]
The requirement to issue a hot work permit, including documentation of necessary fire protection and prevention measures, is currently in the RMP regulation only for Program 3 processes. Under 40 CFR 68.85(b), “The permit shall be kept on file until completion of the hot work operations.” Under the existing RMP regulations, it can be difficult
EPA initially looks to the latest version of industry codes, standards, and guidelines to determine whether an owner or operator has documented compliance with RAGAGEP under 40 CFR 68.65(d)(2), given that 40 CFR part 68 does not define the phrase “recognized and generally accepted good engineering practices.” EPA believes this application makes sense because the
The current definition of “retail facility” at 40 CFR 68.3 is “a stationary source at which more than one-half of the income is obtained from direct sales to end users or at which more than one-half of the fuel sold, by volume, is sold through a cylinder exchange program.” The period of sales to end
Currently, under 40 CFR 68.3, the term “stationary source” does NOT apply to transportation activities, including storage incident to transportation for any regulated substance or any other extremely hazardous substance. A stationary source does include transportation containers connected to loading/unloading equipment or used for storage, not incident to transportation. Still, the term “storage, not incident
Why GAO Did This Study? Over 11,000 RMP facilities across the nation have extremely hazardous chemicals in amounts that could harm people, property, or the environment if accidentally released. Risks to these facilities include those posed by natural hazards, which may damage the facilities and potentially release the chemicals into surrounding communities. Climate change mayAccording
Ammonia (CAS# 7664-41-7) is an Extremely Hazardous Substance (EHS), listed at 40 CFR Part 355 Appendix A EPA website and Appendix B with a reportable quantity (RQ) of 100 lbs. Both ammonia and ammonium hydroxide (CAS# 1336-21-6) are listed as Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) hazardous substances at 40 CFR 302.4. Under
The RMP Amendments, finalized on January 13, 2017, included a requirement for owners or operators of a stationary source to engage in emergency response coordination activities (40 CFR §68.93). The regulatory text in 40 CFR §68.10(b) states that compliance with these activities must be completed by March 14, 2018. Because the RMP Amendments were not
Most formally educated or well-trained safety professionals are familiar with the Hierarchy of Controls. We use this approach daily in our work to reduce the likelihood of an event and/or the event’s severity. Mr. Kletz always had a different take on using this philosophy in process safety and as always – he nailed it!
Light hydrocarbon was released through a pinhole breach of an insulated process pipe. A plant operator detected an abnormal hydrocarbon odor and immediately responded as per site emergency protocol. A localized possible breach was identified, and the processing unit was safely shut down for further investigation. A 3-inch insulated pipe connecting process piping to
The CSB promulgated its Accidental Release Reporting Rule to help the CSB decide when to initiate an investigation into an accidental release, including whether to deploy a team of investigators to the site to do “all things necessary and proper” to initiate an investigation and obtain critical information about the incident. Upon arriving at the
The best birthday present a process safety engineer could ask for; especially on a birthday when a client is dealing with a tragedy. OSHA has “officially” announced the potential changes to the scope of the current PSM standard it is considering:
