The definition of a process would seem to say that my process is part of the larger company’s process because they are interconnected. Why can’t the larger company just include my process in its RMP?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
Must a stationary source owner or operator consider the amount of ammonia present in ammonium hydroxide that is contained in a process when determining whether the threshold for ammonia is exceeded? The list of regulated toxic substances at 40 CFR Section 68.130 includes BOTH “ammonia (anhydrous)” and “ammonia (conc 20% or greater)” but does not…...
Under OSHA’s Process Safety Management Standard, an exemption is provided for the atmospheric storage of flammable liquids. Why has EPA decided NOT to include this exemption under the risk management program regulations?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
I have written often about this topic and it is without a doubt the most questioned/challenged topic in my 5-Day Advanced Process Safety course. Several toxic substances are listed as regulated substances under 40 CFR §68.130 with CONCENTRATION QUALIFIERS (e.g., “conc 37% or greater”). The four(4) regulated substances that have concentration qualifiers are: Ammonia (conc…...
The wonderful team of process safety engineers “across the pond” in the UK have published an EXCELLENT and MUST READ guide on how a business can develop their process safety LEADING indicators. This is a MUST READ for those PS Leaders who are looking for ideas on what and how to measure PSM/RMP Leading Indicators. …...
HAZMAT containers used for flammable, corrosive, and toxic liquids and gases will have a pressure/vacuum relief valve to prevent damage to the tank from changes in the internal pressure. These valves MUST be inspected and maintained in line with the manufacturer’s instructions. Some valve designs require a special tool to dismantle them for servicing. Investigations…...
Investigation into an explosion of a High-Voltage (HV) circuit breaker indicated that recently carried out maintenance may have been a causal factor. The incident resulted in catastrophic failure of the HV circuit breaker leading to fire/explosion and could have resulted in fatal injuries. Maintenance of HV and LV circuit breakers typically involves both the cleaning…...
Way back in my day as a site safety manager, one day I had a knock-down-drag-out with the facility maintenance manager regarding overdue piping inspections. It was not long before my Plant Manager stopped by for a chat. Apparently, the maintenance manager was not too happy having the lowly safety manager expect him to carry…...
If you deal with emergency planning and response to releases of hazardous substances you can take a deep breath and have a sigh of relief… OSHA is NOT touching its HAZWOPER standard under its proposed revision to its emergency response standards. The changes OSHA is proposing will apply ONLY to its Fire Brigade standard, 1910.156. …...
As you know, I am a huge fan of the FM Global Data Sheets and I still recommend them to all my clients. If your business is too cheap to buy RAGAGEPs, these Data Sheets are by far your next best options as they are FREE. And in some situations, I actually prefer the FM…...
Who might be covered by a new Emergency Response standard? The draft Emergency Response standard would apply to employers that mitigate a hazard in an emergency response situation and the activity is currently covered by 29 CFR 1910.156, or is not covered by another OSHA standard. The standard would apply to, but not be limited…...
Have you seen OSHA’s proposed ER standard? It will replace 1910.156 and encompass all aspects of emergency response, such as firefighting, fire rescue, emergency medical service, technical rescue (rope/high angle, cave, etc.), vehicle/machinery rescue, water rescue/recovery (land/shore-based, Swiftwater, underwater), search and rescue (urban, mountain, wilderness). I have gone through the proposed standard and structured it…...
