As I stated last week and posted my updated RMP Audit Checklist ER questions, the RMP ER coordination activities should be at least in your “planning/discussion” phase with your off-site responders/resources. Even though 68.10(b) states that compliance with these activities must be completed by March 14, 2018 and the fact that the amendments did not…...
Back in December 2017, I wrote an article explaining how this new nitrification inhibitor in the ammonia fertilizer industry would impact the facility’s PSM/RMP programs. I received a lot of questions and nasty grams from that article, but one thing I forgot to mention is how this new “blending” operation changes the retail locations EPCRA…...
For SAFTENG clients and members, I have updated my PSM/RMP audit checklist (the old OSHA PQV checklist) with EPA’s most recent amendment regarding the Emergency Response requirements for Responding and Non-Responding facilities. Keep in mind that these new requirements are “officially” ONLY required when the facility is an RMP facility; if the process(s) is ONLY…...
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One (1) bolt on a five(5) bolt flange was left loose by just one full turn and we have a small release of a flammable gas… EXCELLENT video by Baker Risk…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
I do a lot of work in Ammonia and Chlorine, from process safety to emergency response, and the one thing I commonly get asked is why do I write so much about ammonia accidents and not so much about chlorine accidents. Well, to be honest, the vast majority of my chlorine clients are much better…...
For nearly 25 years I have seen CLOSED relief systems used successfully on a multitude of processes involving Extremely Hazardous Substances (EHS) and for many years I have been proposing they be used in the Ammonia Refrigeration industry. The leading trade group for ammonia refrigeration has had a long-standing position against the need for hydrostatic…...
We visit this topic once again as I have already spent time with a “former client” who is now in a serious bind with both OSHA and EPA after a significant Chlorine (Cl2) release. They are a former client as they fired me after a 5-year PHA and 3-year audit a number of years ago. …...
First, let me state that this construction standard has never been cited. This is based on my personal knowledge and the OSHA database; however, it is still in effect and could be cited. Last year, OSHA revised their standards and they simply did away with the duplicate language in 1926.64 and said to follow the…...
Although anhydrous ammonia is an effective refrigerant, it is also a toxic chemical that can injure or kill people when accidentally released. The death of a worker at a Seafood plant in South Boston in 2016 is the most tragic example recently here in New England. In 2018, the U.S. Environmental Protection Agency (EPA) launched a…...
The risk management program regulations require the owner or operator of a covered stationary source to develop and implement an emergency response program as described in 40 CFR §68.95, which MUST include: an emergency response plan, emergency response equipment procedures, employee training, and procedures to ensure the program is up-to-date. But do all facilities subject…...
Must an owner or operator conduct and document a compliance audit at the time of an update required under §68.190 if the update is made within three years of the original RMP submission?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
