Chemical Process Safety (PSM/RMP)

The Use of Metrics in Process Safety Management (PSM) Facilities (OSHA Fact Sheet)

Metrics are measures that are used to evaluate and track the performance of a facility’s process safety management program. For facilities that handle highly hazardous chemicals, metrics can be used to quantify how a process has performed historically, how it might perform in the future, and where improvements can be made to keep workers safe…....

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UPDATE on Chemical Facility Anti-Terrorism Standards Top-Screens and Security Vulnerability Assessments (SVA)

Earlier this year, the Department of Homeland Security (DHS) temporarily suspended the requirement to submit Chemical Facility Anti-Terrorism Standards Top-Screens and Security Vulnerability Assessments (SVA) in order to allow for a phased rollout of the new Chemical Security Assessment Tool (CSAT) 2.0 surveys and enhanced risk tiering methodology. On October 1, 2016, the requirement to…...

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Senator Boxer (D-CA) sends letter to EPA calling on the agency to strengthen their RMP revisions

This week Senator Barbara Boxer (D-CA), Ranking Member of the Environment and Public Works Committee, sent a letter to the Environmental Protection Agency (EPA) calling on the agency to strengthen the proposed revisions to the Risk Management Plan rule. Specifically, she wants the following prevention requirements added to the rule before it is finalized (apparently…...

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OSHA loses their battle to redefine “retail” in the PSM Standard (1910.119)

Friday morning (9/23/16) the United States Court of Appeals, For the DISTRICT OF COLUMBIA CIRCUIT announced that OSHA could not redefine “retail” using a Letter of Interpretation (LOI) or Memorandum, OSHA would have to go through the Notice of Public Rule Making (NPRM) in order to redefine the term.  Ironically, it was a 1995 LOI that actually…...

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RMP Accident Data (2006-2016)

In the last 10 years, RMP data show that there have been more than 1,500 reportable accidents, about 500 of which had off-site impacts. These accidents are responsible for nearly 60 deaths, some 17,000 people were injured or who sought medical treatment, almost 500,000 people evacuated or sheltered-in-place and more than $2 billion in property…...

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Catastrophic Failure of 500 ton Atmospheric Refrigerated Anhydrous Ammonia Tank (2016)

11/22/2017 UPDATE  – Nice write-up Dap-1 Ammonia Tank Explosion: Safety and Security Concerns in Chemical Process Plant in Bangladesh Two DAP officials found guilty – an engineer and the general manager of the plant were found responsible for the accident.  The accused have been found guilty of negligence in duty as they did not inspect the safety…...

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Can my PSM covered process be a RMP Program 1 process?

Absolutely it can, and allow me to explain how.  We start our Risk Management Plan (RMP) program(s) level assessment with Program 1, then if our process(s) does not qualify for Program 1 we ask ourselves if our process(s) would be a Program 3, and then if the process does NOT qualify for Program 1 or 3, then…...

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Do I have to count the quantities of my RMP covered chemicals in railcars sitting on my site?

We don’t see this often, so I feel it is worthy of posting this RMP Citation.  I have written several articles about this and posted a couple of citations.  This one was just posted this week… Process Safety Information [40 C.F.R. 68 .65(c)(l)(iii)] – $300 [Facility] failed to include quantities containing regulated substances purchased for its facility…...

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FATAL Hotwork Explosion @ pipeline station ($1.6 million for failure to follow facility procedures)

On October 8, 2015, a pipeline facility in LA experienced a reportable incident that resulted in a series of explosions, fire, four fatalities, two injuries, evacuations of nearby residences and closure of a state highway. Representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS) Southwest Region (SWR), responded to…...

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HFO-1234yf refrigerant may end up in New Zealand Refrigerators and Home ACs

New Zealand’s EPA is seeking submissions on an application to import a heat transfer gas to be used for refrigeration and air conditioning. The gas – HFO-1234yf – is for use in refrigeration and air conditioning systems in commercial and domestic settings, including in cars. The applicant, Honeywell International Inc, has applied to import HFO-1234yf…...

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California Governor’s Office of Emergency Services extends CalARP Program 4 written comment deadline

The California Governor’s Office of Emergency Services published a Notice of Proposed Action in the July 15, 2016 edition of the California Regulatory Notice Register (Register 2016, No. 29-Z, p. 1207) concerning the CalARP Program 4. The original comment period deadline was August 29, 2016.  The Office is extending the written comment deadline to September 15, 2016…....

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