Although I agree with most of EPA’s FAQs regarding their RMP standard, this one is just sad! The question was asked… Are Mechanical Controls Considered Administrative Controls? EPA and I could not be further apart on this topic, as EPA actually stated they would NOT accept an engineered hi-level alarm/interlock and would only accept a […]
EPA will, according to the regulations at 40 CFR §68.220(b), select stationary sources for audits based on any of the following criteria:
The prevention program requirements under 40 CFR Part 68, Subparts C and D, include “hazard reviews” and “process hazard analyses”. Is a “hazard review” synonymous with a “process hazard analysis” (PHA)? No, and here is the difference…
If an incident caused by theft or other criminal activity at a covered facility resulted in or could reasonably have resulted in a catastrophic release of a regulated substance, then the owner or operator of the covered facility must perform an incident investigation. If it would be unreasonable, based on the owner/operator’s knowledge of the
One of the top questions we get and it goes to HAZARDOUS MATERIALS MANAGEMENT! We have an EHS/HHC on site and today we are under the PSM and RMP TQ’s – KEEPING in mind that the standards have different TQ’s for many of the EHS/HHC’s. But if we do not manage these inventories AND cap
I have had seen dozens of facilities covering (albeit very poorly) a process that is NOT a PSM/RMP covered process because some consultant told them it was. The consultant(s) would point to an old statement by EPA that the Threshold Quantity (TQ) determination was based on the process’s ability to hold an amount exceeding the
EPA attempts to define and quantify how far apart separate vessels have to be to be considered different processes. There is no hard-and-fast rule for how great this distance should be before you can consider the vessels as part of one process.
Yes, I’m well aware that EPA has officially stated that an Org Chart showing who is responsible for the various elements is all that is need to “comply”. But in an actual functioning process safety management system, we will not only define who is responsible for each element but we will also explain HOW each
We have all been there… the auditor identified several “physical changes” during their walk-thru of the process, and when it comes time to audit the MOC element, they begin asking for completed MOCs (and PSSRs). And like everyone before us and mostly after us, we will have made changes that needed a MOC, but we
OSHA’s and EPA’s process safety standards require a lot of specific training in order to meet their minimum compliance requirements; however, in this article, I want to point out that although OSHA or EPA makes no specific mention of this training, the training is ABSOLUTELY NECESSARY for a functioning process safety management system.
After cleaning with steam a tank was quenched with cold water to shorten the cooling time (not normal practice). The tank vent was not calculated for the vacuum resulting from this rapid quenching operation, resulting in a collapsed tank (without liquid release). SOURCE: EPSC Learning Sheet
Back in May 2020 and January 2021, I posted the first two parts of this three-part series on the hazards of Liquid Nitrogen. These articles were prompted by the OSHA and State Fire Marshal cases involving fatalities at cattle and human sperm bank businesses. Then, in January of this year, we had the GA Food
