Last week I posted a June 2016 OSHRC decision in which an Administrative Law Judge (ALJ) sided with OSHA on a number of PSM citations regarding a fatal boiler explosion that occurred within a PSM-covered process. Since that posting, I have received dozens of e-mails asking for more explanation and how I suggest managing this […]
This case is not final orders of the Review Commission as it is pending Commission Review! This decision can have HUGE impacts throughout the PSM/RMP community, as many covered processes are “interconnected” to a boiler and many may also be “co-located” such that a boiler explosion could impact the covered process. This case involved a boiler
This week I was privileged to be able to present as ASSE’s Safety 2016 on a topic near and dear to me… Line Break/Process Opening. In our presentation, we mentioned “Routine vs. Non-Routine Openings” and how we manage these different openings. One of the requests we received afterward was for “routine openings” that resulted in
This is the latest version of the Chemical Reactivity Worksheet (CRW) 4.0.0, which was posted on March 3rd, 2016 . Follow these instructions for downloading, installing, and running the CRW. NOTE: With the release of CRW 4.0 in March 2016, the ongoing management and distribution of the CRW have been transitioned to The Center for
Respondent owns and operates a chemical manufacturing facility that has an Acrylonitrile Manufacturing process. On or about December 1-3, 2015, an EPA inspector conducted an inspection of Respondent’s facility. A contractor was removing a six-inch blind and installing four-inch and three quarters inch blinds to prepare the Heads Column in the Acrylonitrile Unit for caustic cleaning. The
In 2015, Congress passed the Federal Civil Penalties Inflation Adjustment Act Improvements Act to advance the effectiveness of civil monetary penalties and to maintain their deterrent effect. The new law directs agencies to adjust their penalties for inflation each year using a much more straightforward method than previously available, and requires agencies to publish “catch
Every once in a while we come across process vessels that are operating well above 15 psi and yet the vessel has no recognized design criteria and is far from being an ASME “coded vessel”. Most of the time the client is happy we discovered this, but there are those who will always challenge the
Thanks for everyone’s positive feedback. As promised here are the files we promised…
One of the top items from our process safety audits, PHAs, assessments, etc. is the lack of vehicle protection around critical equipment/infastructure. Number one target in process plants is overhead piping! It seems no matter how high we put it, it will get hit. Already this year we were told that the pipe bridge over
One of the top questions I receive is asking about how NFPA 704 ratings play into the application to OSHA’s Process Safety Management standard and EPA’s Risk Management Plan rule. I hope to clarify any confusion this NFPA 704 application may be causing, as YES – the NFPA 704 does have a role in determining if
Respondent owned and operated a refinery. On March 31-April3, 2014, EPA Region 6 conducted an unannounced, onsite CAA 40 C.F.R. Part 68 and Section 112(r) Partial Compliance Evaluation of the Facility. The refinery submitted a single RMP with covered processes that are subject to Program 3 requirements. The regulated flammable substances that are above the threshold
