Whether we’re in process safety or just good ole fashioned occupational safety and health, the act of performing hot work (welding to the layperson – my feeble attempt at some Dumb and Dumber humor) can be one of the most dangerous task workers can perform. Add in the fact the hot work is done within […]
Here is an initial look at the rule, signed by the CSB Interim Executive today. The final rule requires an owner or operator of a stationary source to submit an accidental release report to the CSB. The rule describes when to file a report of an accidental release and the required content of such a
The Risk Management Program (RMP) regulations require the owner or operator of a stationary source to revise and update the source’s RMP at least once every five years from the date of its initial submission or most recent full update (§68.190(b)). Is there a procedure for obtaining an extension to complete the five-year review?
The Risk Management Program emergency response coordination activities require the owner and operator of a stationary source to provide to the local emergency planning and response organizations: the stationary source’s emergency response plan if one exists; emergency action plan; updated emergency contact information; and any other information that local emergency planning and response organizations identify
How much time does the owner or operator of a stationary source have to submit a correction to a Risk Management Plan when the emergency contact information changes? The Risk Management Plan (RMP) regulations require an owner or operator of a stationary source to correct their RMP within one month (i.e., 30 days) of any
The following is a list of key safety measures developed by EPA in coordination with the International Institute of Ammonia Refrigeration (IIAR). They are measures that EPA and IIAR agree are required elements for ammonia refrigeration facilities (regardless of an ammonia refrigeration system’s age or size) for the system to meet the requirements of 40
First I want to thank my Pittsburg friends for another great visit and for being my “think-tank” of world-class engineers and chemists. I always leave smarter and happier after my time with these folks. And with all my visits I always come away with great real-world examples of how process safety is supposed to be
During stakeholder outreach as part of EO 13650 and during OSHA’s PSM SBREFA (Small Business Regulatory Enforcement Fairness Act), OSHA and EPA received multiple comments from stakeholders expressing confusion on the applicability and overlap between OSHA’s Process Safety Management (PSM) standard and EPA’s Risk Management Plan (RMP) regulation. In the Clean Air Act Amendments of
I have written over a dozen articles on the big change in automobile manufacturing and their new refrigerant HFO-1234yf which is going into almost all vehicles made today. Today HFO-1234yf is a Category 1 Flammable gas, hence it is a Highly Hazardous Chemical (HHC) and when the process exceeds 10,000 pounds of this refrigerant the
“Minor” LOPC events that are allowed to continue over a weekend can be a COSTLY MISTAKE! Any LOPC event MUST be reported ASAP to that it can be addressed, regardless of how “minor” it may be considered! We have to keep our HHC/EHS’s in their PRIMARY CONTAINMENT and when we have a failure that lets
Opening a Natural Gas Condensate line with a battery-operated drill inside a compressor building is ASKING for trouble. Basic HAZLOC work practices include using INTRINSICALLY SAFE tools that are APPROVED for the HAZLOC, which has been an OSHA requirement since 1981… 1910.307(c) Electrical installations. Equipment, wiring methods, and installations of equipment in hazardous (classified) locations
Remember that project where we installed new XXXXXXX and to save money we did not remove the old XXXXX and just piped around it? We always thought that the old piping and valves were not a hazard, well think again… On May 20, 2019, an offshore oil and gas worker was conducting daily rounds, which
