Respondent is the owner and/or operator of the facility, which produces fully cooked and ready-to-eat sauces and refrigerated entrees. On December 26, 2018, the EPA issued to Respondent a Notice of Potential Violation (“NOPV”), providing notice that the EPA found that Respondent potentially committed the alleged violations described in Section V of this Agreement and…...
This is another case where OSHA and EPA compliance may be the least of our concerns, as this is REAL LIFE process safety – NOT compliance work! Yes, we have to comply with our repair RAGAGEP; but I was referring to whether a facility does a MOC or not. Let’s examine this type of work…...
Although I agree with most of EPA’s FAQs regarding their RMP standard, this one is just sad! The question was asked… Are Mechanical Controls Considered Administrative Controls? EPA and I could not be further apart on this topic, as EPA actually stated they would NOT accept an engineered hi-level alarm/interlock and would only accept a…...
EPA will, according to the regulations at 40 CFR §68.220(b), select stationary sources for audits based on any of the following criteria:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
The prevention program requirements under 40 CFR Part 68, Subparts C and D, include “hazard reviews” and “process hazard analyses”. Is a “hazard review” synonymous with a “process hazard analysis” (PHA)? No, and here is the difference…… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
If an incident caused by theft or other criminal activity at a covered facility resulted in or could reasonably have resulted in a catastrophic release of a regulated substance, then the owner or operator of the covered facility must perform an incident investigation. If it would be unreasonable, based on the owner/operator’s knowledge of the…...
One of the top questions we get and it goes to HAZARDOUS MATERIALS MANAGEMENT! We have an EHS/HHC on site and today we are under the PSM and RMP TQ’s – KEEPING in mind that the standards have different TQ’s for many of the EHS/HHC’s. But if we do not manage these inventories AND cap…...
I have had seen dozens of facilities covering (albeit very poorly) a process that is NOT a PSM/RMP covered process because some consultant told them it was. The consultant(s) would point to an old statement by EPA that the Threshold Quantity (TQ) determination was based on the process’s ability to hold an amount exceeding the…...
EPA attempts to define and quantify how far apart separate vessels have to be to be considered different processes. There is no hard-and-fast rule for how great this distance should be before you can consider the vessels as part of one process…. Membership Required You must be a member to access this content.View Membership LevelsAlready...
Yes, I’m well aware that EPA has officially stated that an Org Chart showing who is responsible for the various elements is all that is need to “comply”. But in an actual functioning process safety management system, we will not only define who is responsible for each element but we will also explain HOW each…...
We have all been there… the auditor identified several “physical changes” during their walk-thru of the process, and when it comes time to audit the MOC element, they begin asking for completed MOCs (and PSSRs). And like everyone before us and mostly after us, we will have made changes that needed a MOC, but we…...
OSHA’s and EPA’s process safety standards require a lot of specific training in order to meet their minimum compliance requirements; however, in this article, I want to point out that although OSHA or EPA makes no specific mention of this training, the training is ABSOLUTELY NECESSARY for a functioning process safety management system…. Membership Required...
