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 ยง68.95, which must include an emergency response plan, emergency response equipment procedures, employee training, and procedures to ensure the program is up-to-date. Do all facilities subject to […]
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?
A wise plant manager told me this in my first year in the petrochem industry. I am paraphrasing When it comes to our primary containment systems (he was speaking to piping in this discussion) – if it is not done darn near perfect, all we have to do is wait a while and bad things
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
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.
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
