This week, I am doing my intermediate 3-day process safety training course for a new client whose process HHC/EHS is Liquefied Petroleum Gas (LPG); however, this process is VERY different than the other clients I have whose HHC/EHS is LPG. My clients are END-USERS of LPG; this facility is NOT the user of the LPG;…...
Respondent owns and operates a metal parts heat treatment operation and maintains a maximum inventory of 60,000 pounds of anhydrous ammonia, at the Facility, which exceeds the threshold quantity of 10,000 pounds. Respondent uses anhydrous ammonia in its heat treatment process. EPA inspectors completed an announced CAA 112(r) inspection on June 15 through June 16,…...
Respondent is supplied with raw chemical feedstocks by tanker truck or railcar. Chemical unloading operations occur on the eastern portion of the Facility at dedicated tank truck and railcar unloading stations. Several chemicals are stored in bulk at the Facility in dedicated aboveground storage tanks (ASTs), including, nitric acid (one tank), hydrogen peroxide (four tanks),…...
Respondent operates a granular monoammonium phosphate (GMAP) process and a diammonium phosphate (DAP) process at the Facility, meeting the definition of “process” as defined by 40 C.F.R. § 68.3. A different Respondent operates an anhydrous ammonia process at the Facility, meeting the definition of “process” as defined by 40 C.F.R. § 68.3. The GMAP and…...
I am teaching my 3-Day Intermediate Process Safety course this week, and one of the popular exercises we do on Day 1 is the “Vehicle Safety Challenge.” It is designed to teach students to begin thinking about Layers of Protection within the PREVENT-PROTECT-MITIGATE model. Five students in four (4) groups have 15 minutes to… Membership Required...
The good old “safety incentive program” has been around since man walked upright and has been misleading management since its conception. The concept is valid, based on the old “carrot and the stick” model. There has always been one fatal flaw in these programs… they usually incentivize the WRONG things! The traditional safety incentive programs,…...
One of the top questions we get regarding contractor safety is, “Do I have to evaluate, orientate, and audit subcontractors working for a contractor we hired?”. OSHA’s latest revision of their PSM CPL answered this question. Is the host employer of a PSM-covered facility responsible for the safety of subcontractors?… Membership Required You must be...
Responding to a report of workers being exposed to anhydrous ammonia, federal investigators found a Madison ice cream plant lacked sufficient process safety management procedures to control the release of hazardous chemicals. Investigators with the U.S. Department of Labor’s Occupational Safety and Health Administration determined the Ice Cream facility failed to document that equipment was…...
On December 14, 2023, OSHA published its revised Compliance Directive for Process Safety Management standard 1910.119, effective January 26, 2024. This new version is in Q7A format and was done nicely, although there are a number of things in the answers that I am sure will be challenged. I have highlighted some of the interesting…...
HOP is NOT an Element of a Safety Management System (SMS) HOP principles are HOW we manage our SMS We see a lot of discussions on social media regarding the role of HOP and Psychological Safety, two methods I fully embrace should be used in OSH and PSM. However, I view these two methods…...
Let’s talk about DE-incentivising businesses to properly manage Occupational Safety and Health (OSH), even at the most basic level. OSHA now requires businesses to report their injury and illness logs, which they will use to identify workplaces needing a compliance inspection. They are doing this due to their lack of adequate resources, and they want…...
Sweating the “small stuff” matters in process safety management. Meeting the details of our chosen RAGAGEPs matters! Although I am often told, “That is a picky audit finding,” it is what it is. Far too many facilities believe that designing their process piping to be bolted flange assembly vs. welded joints is somehow easier; in…...
