With all the recent attention being paid to EPA and it’s Risk Management Plan amendments and many of those amendments being rescinded by the new administration, I thought it would be a good time to remind those in the PSM/RMP world, that OSHA has their own wish list (my phrase – not theirs) and some of […]
In the RMP Amendments rule, EPA added three major provisions to the accident prevention program of Subparts C (for Program 2 processes)and D (for Program 3 processes). These included: A requirement in § 68.60 and § 68.81 for all facilities with Program 2 or 3 processes to conduct a root cause analysis using a recognized
EPA monetized both on-site and off-site damages. EPA estimated total average annual on-site damages of $265.8 million. The largest monetized average annual on-site damage was on-site property damage, which resulted in average annual damage of approximately $205.5 million. The next largest impact was on-site fatalities ($49.8 million) and injuries ($10.5 million). EPA estimated total average
Over the years I have facilitated and participated in hundreds of PHAs from toxics to flammables and even some explosives (although not my thing!). And in doing so, one thing that drives me crazy is the lack of structure in how process deviations are identified and studied/analyzed. I love the HAZOP methodology and hate the
This is a common question we get when we are working at facilities where there is a mechanical refrigeration system… Do my refrigeration technicians have to be “qualified electrical workers”? Because that question is so broad, we always answer “Yes”, based on our experience around these types of processes, but it depends and here are
In the EPA Office of Inspector General’s Semiannual Report to Congress: Oct 1, 2017 – March 31, 2018 we see two “recommendations” regarding the manner in which EPA conducts their Risk Management Plan (RMP) audits and how the OIG feels the process could be improved upon. These are a continuation of improvement from the 2013
With this week’s flash fire that sent over 20 workers to the hospital, I thought this video would be timely. This is a demo video by an FRC maker, and it shows us how the vapor and flame interact.
For some reason, we have seen a spike in questions and request to assess the applicability of PSM/RMP covered process(s), and this is beyond the typical “can use the Meer decision to get our flammable process out of PSM?” questions. So I thought it would be helpful to publish OSHA’s official interpretation and explanation of
Respondent owns and operates a food service distribution facility that handles approximately 12,000 pounds of anhydrous ammonia at the Facility. EPA conducted an inspection of the Facility on October 18, 2017 (“Inspection”) to determine Respondent’s compliance with CAA Section 112(r)(7) and the Chemical Accident Prevention Provisions at 40 C.F.R. Part 68. Respondent submitted an initial
This week I have been working with a new member who has become frustrated with all the different directions and “interpretations” regarding OSHA’s and EPA’s Maximum Intended Inventory requirements. This is my e-mail response – names and titles have been changed to protect the innocent! (LOL) I feel your pain, this one small topic has
In FY 2017, OSHA conducted 32,408 inspections, including 18,031 (about 56 percent) unprogrammed inspections, which includes employee complaints, injuries/fatalities, and referrals. The high percentage of unprogrammed inspections indicates that OSHA continues to devote considerable resources responding to referrals and complaints. Of the 32,408 inspections, 14,377 (about 44 percent) were programmed inspections. Programmed inspections focus OSHA’s
