OSHA Compliance

Hydrogen is becoming a popular fuel, and the 2024 IFC provides us with an excellent baseline design for these H2 systems

I have worked with three (3) organizations in the past 5 years on their efforts to make H2 an everyday fuel for household appliances, vehicles, and industrial fuels. Each project was a huge learning experience for everyone! But I am a lover of “codes” to establish the baseline design, construction, operation, and maintenance. I looked […]

Don’t kid yourself, there is NO SMS in place if the facility is not audited on a routine basis (Learning the hard way)

In the context of a Safety Management System (SMS), auditing is the systematic, independent, and documented process for obtaining objective evidence and evaluating it against established criteria to determine the extent to which requirements are fulfilled. I recently had a lengthy discussion with the executive team regarding my PSM/RMP audits over the years. These men

Using 35°F – 50°F dew point compressed air in Hot Oil Boiler piping pressure/leak tests is a serious FAILURE

We get so much slack when we push Hydrostatic Pressure/Leak Testing vs. Pneumatic testing. So many think that pneumatic is easier and cheaper, when in reality it is NOT. In fact, the B31 series makes it clear that HYDROSTATIC is the first choice for pressure and leak testing. The code makes it clear that pneumatic

Facility Siting 101 – Spacing of Flammable Liquid Storage Tanks (updated with MMA event)

OSHA, IFC, and NFPA have “separation distance” requirements for flammable liquid storage tanks. These requirements have been around longer than I have been dealing with hazardous materials and process safety, and yet we always come across some wildly out of “compliance” arrangements of these flammable liquid tanks. using OSHA’s Flammable Liquid Standard 1910.106 we can

MMA Storage Tanks Design

Storing Methyl Methacrylate (MMA) requires a delicate engineering balance. Because it is both a Class IB Flammable Liquid and a Class 2 Unstable Reactive, the storage design must simultaneously mitigate the vapor-fire hazard while actively feeding the chemical inhibitor to prevent thermal runaway. When evaluating bulk storage tanks from a Process Safety Management (PSM) perspective,

Can we use ACGIH TLVs/NIOSH RELs in the MUC formula rather than OSHA’s PELs?

The simple answer is yes, we can use ACGIH TLVs or NIOSH RELs to calculate the Maximum Use Concentration (MUC), but with one ABSOLUTE regulatory caveat: The resulting limit must be more protective (stricter) than what the OSHA standard dictates, or be applied to a chemical that OSHA does not currently regulate. Under 1910.134(b), OSHA

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