Recently a former client was cited for hiring a contractor who was not qualified for the work they were hired to perform. Also, do not lose sight of the fact that this contractor was NOT cited for any OSHA violation as they did not violate their responsibilities under 1910.119(h)(3), although some may argue they violated […]
Some chemical warehouses and distribution facilities may be failing to properly manage hazardous chemicals as required by federal law. In the past several years, the EPA has visited numerous chemical warehouses and distribution facilities (i.e., companies that process, formulate, blend, re–package, store, transport, and market chemical products) to determine compliance with the Clean Air Act
EPA is adding natural gas processing (NGP) facilities (also known as natural gas liquid extraction facilities) to the scope of the industrial sectors covered by the reporting requirements of the Emergency Planning and Community Right-to-Know Act (EPCRA), commonly known as the Toxics Release Inventory (TRI), and the Pollution Prevention Act (PPA).
A catastrophic incident at an engineering facility serves as a definitive case study in the dangers of improper pressure testing. A technician suffered life-altering injuries when a 335-liter (88-gallon) vessel exploded during a pressure test. The root cause was a fundamental failure in hazard control: the company opted to use compressed air (pneumatic testing) instead
This has been a huge battle in the power generation and semi-conductor industries! To me, it is very clear – as soon as the trailer is “dropped”, meaning the semi that was pulling the tube-trailer has been detached, then that trailer becomes a “stationary process”. EPA has several documents making this point and for those
Formaldehyde is not specifically listed with a concentration cutoff, but is listed with the QUALIFIER “solution”. Can the partial pressure exemption be applied to formaldehyde solutions?
The definition of a process would seem to say that my process is part of the larger company’s process because they are interconnected. Why can’t the larger company just include my process in its RMP?
Must a stationary source owner or operator consider the amount of ammonia present in ammonium hydroxide that is contained in a process when determining whether the threshold for ammonia is exceeded? The list of regulated toxic substances at 40 CFR Section 68.130 includes BOTH “ammonia (anhydrous)” and “ammonia (conc 20% or greater)” but does not
Under OSHA’s Process Safety Management Standard, an exemption is provided for the atmospheric storage of flammable liquids. Why has EPA decided NOT to include this exemption under the risk management program regulations?
I have written often about this topic and it is without a doubt the most questioned/challenged topic in my 5-Day Advanced Process Safety course. Several toxic substances are listed as regulated substances under 40 CFR §68.130 with CONCENTRATION QUALIFIERS (e.g., “conc 37% or greater”). The four(4) regulated substances that have concentration qualifiers are: Ammonia (conc
The wonderful team of process safety engineers “across the pond” in the UK have published an EXCELLENT and MUST READ guide on how a business can develop their process safety LEADING indicators. This is a MUST READ for those PS Leaders who are looking for ideas on what and how to measure PSM/RMP Leading Indicators.
HAZMAT containers used for flammable, corrosive, and toxic liquids and gases will have a pressure/vacuum relief valve to prevent damage to the tank from changes in the internal pressure. These valves MUST be inspected and maintained in line with the manufacturer’s instructions. Some valve designs require a special tool to dismantle them for servicing. Investigations
