I am in no way a big government kind of guy, but I do believe in having an established set of rules (most safety rules) by which all players must play by. Earlier this year in Boston, MA there was a fatality at a seafood processing facility caused by a release of Anhydrous Ammonia (NH3) from the refrigeration process. A couple of months ago, OSHA issued their citations that included 20 serious violations; however, missing from these citations was any Process Safety Management (PSM) violations, due to the fact that the process (assumed) to contain less than the 10,000 pounds of NH3 required for PSM to apply. But fear not, the government has this covered, because back in the 2010-2012 timeframe, and based on recommendations from the Chemical Safety Board, the State of MA implemented 527 CMR 33.00-Hazardous Material Process or Processing. CLICK HERE to read more about this state code. But as we wrap up 2016, there appears to be no actions taking place regarding enforcing this state code against the employer that had the fatal NH3 release.
I have contacted the state FM office and even asked for some local reporters in the Boston area to help me track down any enforcement action by the state using 527 CMR 33.00-Hazardous Material Process or Processing. The state FM did not respond and the reporters came up emtpy on finding any activity. So here we have a state government passing a code in the name of safety but it appears to be nothing more than a “tax” on buisnesses.
