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This is another case where OSHA and EPA compliance may be the least of our concerns, as this is REAL LIFE process safety – NOT compliance work! Yes, we have to comply with our repair RAGAGEP; but I was referring to whether a facility does a MOC or not. Let’s examine this type of work and you may be surprised at my answer to “Is a MOC required when making repairs to an...
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Although I agree with most of EPA’s FAQs regarding their RMP standard, this one is just sad! The question was asked… Are Mechanical Controls Considered Administrative Controls?
EPA and I could not be further apart on this topic, as EPA actually stated they would NOT accept an engineered hi-level alarm/interlock and would only accept a written procedure to control inventory involved...
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EPA will, according to the regulations at 40 CFR ยง68.220(b), select stationary sources for audits based on any of the following criteria:
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The prevention program requirements under 40 CFR Part 68, Subparts C and D, include “hazard reviews” and “process hazard analyses”. Is a “hazard review” synonymous with a “process hazard analysis” (PHA)?
No, and here is the difference…
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If an incident caused by theft or other criminal activity at a covered facility resulted in or could reasonably have resulted in a catastrophic release of a regulated substance, then the owner or operator of the covered facility must perform an incident investigation. If it would be unreasonable, based on the owner/operator’s knowledge of the facility and the safeguards that are in place, to...
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One of the top questions we get and it goes to HAZARDOUS MATERIALS MANAGEMENT! We have an EHS/HHC on site and today we are under the PSM and RMP TQ’s – KEEPING in mind that the standards have different TQ’s for many of the EHS/HHC’s. But if we do not manage these inventories AND cap the amount we allow on-site, we will get burned one day and I do not mean in the...
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I have had seen dozens of facilities covering (albeit very poorly) a process that is NOT a PSM/RMP covered process because some consultant told them it was. The consultant(s) would point to an old statement by EPA that the Threshold Quantity (TQ) determination was based on the process’s ability to hold an amount exceeding the EHS TQ(s). This was grossly incorrect and just this year...
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EPA attempts to define and quantify how far apart separate vessels have to be to be considered different processes. There is no hard-and-fast rule for how great this distance should be before you can consider the vessels as part of one process.
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Yes, I’m well aware that EPA has officially stated that an Org Chart showing who is responsible for the various elements is all that is need to “comply”. But in an actual functioning process safety management system, we will not only define who is responsible for each element but we will also explain HOW each element will be managed. 99.99% of the written programs we see...
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We have all been there… the auditor identified several “physical changes” during their walk-thru of the process, and when it comes time to audit the MOC element, they begin asking for completed MOCs (and PSSRs). And like everyone before us and mostly after us, we will have made changes that needed a MOC, but we failed to perform one. This leads to an audit finding and...
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OSHA’s and EPA’s process safety standards require a lot of specific training in order to meet their minimum compliance requirements; however, in this article, I want to point out that although OSHA or EPA makes no specific mention of this training, the training is ABSOLUTELY NECESSARY for a functioning process safety management system.
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A central Illinois grain-handling cooperative exposed workers to serious engulfment hazards when soybeans collapsed inside a bin and engulfed an employee up to their waist. An investigation by OSHA found that two workers were clearing the bin of crops and debris when the February 19, 2021, incident occurred. OSHA proposed $303,510 in penalties after identifying three (3) willful, one (1) serious,...
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