Does the title make you scratch your head? I usually get some strange looks when working with a client who is trying to understand what the PSM compliance cycle looks like. To start with, let’s look at what OSHA/EPA requires in our operating procedures: 1910.119(f)(1)(ii) Operating limits 1910.119(f)(1)(ii)(A) Consequences of deviation 1910.119(f)(1)(ii)(B) Steps required to…...
If your PSM/RMP covered process contains a flammable liquid, 1910.106 has provided us with some regulatory facility siting requirements that we can quickly inspect to ensure we meet the minimum compliance distances. If you have liquefied petroleum gases within your facility, 1910.110 provides some basic siting requirements that should be met to have an argument…...
Many chemical processes that are covered under OSHA’s PSM and EPA RMP rules utilize one of the most popular forms of passive mitigation ever known…Diking. However, on the other hand, many of the facilities have not included their dikes in their Process Safety Information (PSI) or their Mechanical Integrity Programs (MIP)…. Membership Required You must...
I had an interesting dissertation given to me on how to calculate “frequency” when analyzing a PHA scenario during a recent PHA. Although it sounded logical, it was completely off base and thus would have shown the facility at very low risk for all their scenarios. This is something we see from time to time…...
Since the great recession of 2008 -2010 we have seen an increase in the used equipment market. This is due to so many businesses going under and auctioning off their equipment and the remaining businesses needing to find ways to save $…. Membership Required You must be a member to access this content.View Membership LevelsAlready...
So, who is responsible for Confined Space Evaluations, and when must they be conducted? The short answers are ALL General Industry (1910) employers, and at the time the standard was promulgated, and before each entry. Let me explain…… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in...
One of the most frequently asked about standards is OSHA’s Permit-Required Confined Space (PRCS) standard. The standard can be challenging to decipher, so this post attempts to break down an employer’s entry options. We should view the standard as offering three (3) entry options. Each option has its own set of rules and pros and…...
Like many safety professionals, I learned there is a HUGE difference in flammable liquids the HARD WAY. Having a strong background in fire/HAZMAT, even as an IFSTA instructor 20 years ago, I thought flammable liquids were all about flash points and LEL. To an emergency responder, that may work, but as a safety engineer responsible…...
Now here is why bonding and grounding falls well short of being all the precautions we need when transferring NON-CONDUCTIVE FLAMMABLE LIQUIDS. Bonding and grounding takes into account that we are equalizing the energy levels between the containers and therefore the static will not be released to the differently charged container. This works when it…...
A Purdue University report showed 51 grain bin accidents last year, up from 38 in 2009 and the most since tracking began in 1978. Twenty-five people died, and five of them were children under the age of 16. The previous record for grain bin accidents was 42 in 1993. The accidents prompted the OSHA to…...
The National Board of Boiler and Pressure Vessel Inspectors has released the Violation Findings Fourth Quarter Report for 2010. The report is based on 65 reports from 38 jurisdictions, consists of 170,643 inspections with 17,201 violations. This is a 10% violation rate…. Membership Required You must be a member to access this content.View Membership LevelsAlready...
Fundamental safety management failings were the root cause of Britain’s most costly industrial disaster, a new publication reveals. The report into the explosion and five-day fire at the Buncefield Oil Storage Depot in December 2005 tells for the first time the full story of the Health and Safety Executive (HSE) and Environment Agency’s (EA) investigation…....
