As an initial step, and prior to publication of any proposed changes to existing rules or enforcement policies, OSHA is convening a Small Business Advocacy Review Panel (“SBAR Panel”) in accordance with the Regulatory Flexibility Act, or RFA (Sections 601 through 612 of Title 5 of the United States Code). This Panel consists of members from OSHA, the […]
The Process Safety Management (PSM) standard is intended to prevent or minimize the consequences of catastrophic releases of highly hazardous chemicals (HHCs). It requires employers to adopt a comprehensive management program that integrates technologies, procedures, and management practices to help assure safe and healthy workplaces. OSHA is considering revisions to the PSM standard, including changes
Last week OSHA shared an update on where they are at with their desired revisions to the PSM standard (1910.119). Some of the potential PSM Revisions include: Atmospheric Storage Tanks Oil and Gas-Well Drilling, Servicing, and Production Chemical Reactivity Safer Technology and Alternatives Additions to Appendix A Chemicals Dismantling/Disposal of Explosives Define/Updating RAGAGEP Mechanical
Back on March 4, 2016 a contractor/truck driver was transferring “diesel fuel” of some type from a storage tank to his truck when there was a flash fire. He received 2nd and 3rd degree burns over 50% of his body and has since passed away from his injuries. When I saw this incident in my
We have seen this far too often… operating ranges that are too close to RV set points. Here is some excellent guidance from a great pressure vessel RAGAGEP, the National Board (NBIC-Parts 1-3) on how to establish the DESIGN characteristics for a pressure vessel based on the OPERATING PARAMETERS the vessel will be operating in…
Both OSHA and EPA require PSM/RMP facilities, more specifically covered process(s), have a QA program in their Mechanical Integrity (MI) Program… 1910.119(j)(6) Quality assurance. 1910.119(j)(6)(i) In the construction of new plants and equipment, the employer shall assure that equipment as it is fabricated is suitable for the process application for which they will be used. 1910.119(j)(6)(ii) Appropriate checks
Background: You’ve pointed out that in some workplaces, employees may be required to wear a different harness on the same manufacturer’s model facepiece and sealing surface for different work scenarios such as different work modes (negative vs. positive pressure) or for flame and heat protection. During our meeting, we discussed… One respirator model has two
As a process safety professional, what do we see and what comes to mind when we see a pipe flange like the one shown here? In this small and simple picture, how many sections of OSHA’s PSM standard (or EPA’s RMP rule) impact this pipe flange; better yet, can we name all the RGAGEPS that
I just hope I can convince other safety professionals that atmospheric storage tanks containing flammable liquids are EXTREMELY DANGEROUS and deserve our respect when it comes to DESIGN, CONSTRUCTION, FACILITY SITING, and MAINTENANCE (e.g. MI), and RELIEF PROTECTION. I recently had a lawyer attempt to make an argument that if these tanks were so dangerous
