One of the recent amendments of EPA’s RMP rule impacted our Incident Investigation procedures/practices and most likely any report forms we had been using for years and years. The RMP and PSM Incident Investigation elements used to be very similar and thus most of us used the same procedure/practices and forms when trying to comply with the two (2) elements. But now, since EPA had to implement...

Respondent owns and operates a chemical facility which had Chlorine (Cl2) as its “regulated substance”.  On or about January 23-24, 2018, representatives of the EPA conducted an inspection of Respondent’s Facility to determine compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68. Information gathered during the EPA inspection revealed that Respondent had greater than...

I like direct statements and clear concise rules when it comes to drawing the lines of safety and production and maintenance.  But too often, these lines get drawn in the wrong spot and cause safety all kinds of issues and let’s admit it… gives safety a bad name.  One such line is when lockoout/tagout (LOTO) applies.  We can not just state that LOTO applies for all “servicing...

It is important to emphasize that the machine guarding requirements of 29 CFR Part 1910, Subpart O standards COMPLEMENT THE REQUIREMENTS for LOTO. In some instances, an employer may avoid the requirements of the LOTO, if they ELIMINATE exposure to servicing and maintenance hazards by using machine guarding techniques compliant with those standards.   It is also important to...

Lockout/Tagout (LOTO) STARTS WITH machine gaurding. Yes, MACHINE GAURDING – we can not even begin to speak of LOTO until we first have the forms of hazardous energy properly gaurded for our NORMAL OPERATIONS.  Because when the machine/equipment is being used for its inteded purpose(s) (e.g. Normal Operations) we are FIRST REQUIRED to ensure that all forms of “hazardous energy”...

The state of NJ has developed a Toxic Catastrophe Prevention Act (TCPA) Program Update intended to assist regulated TCPA facilities in understanding how they are impacted by the January 13, 2017, amendments to EPA’s RMP Rule, 40 CFR Part 68. The table indicated the effective dates of the amendments, which provisions are incorporated by the TCPA Program, the actions required by TCPA registrants,...

This Consent Agreement and Final Order serves as notice that the EPA has reason to believe that Respondent violated the General Duty Clause set forth in Section 112(r)(1) of the CAA and the Chemical Accident Prevention Provisions in 40 C.F.R. Part 68 and that Respondent violated Section 112(r) of the CAA. Respondent’s Facility has ceased all operations. On or about May 15 -17, 2017, the EPA conducted...

Download CAMEOfm 3.5.1 at https://www.epa.gov/cameo/cameo-software Note: If you’re upgrading to CAMEOfm 3.5 from a previous version of CAMEOfm, follow the instructions in the guidance document (provided on the download page) to ensure that you don’t lose your current data. What’s changed in CAMEOfm 3.5.1? Version 3.5.1 resolves an issue in which the program could not import an XML...

There are not very many OSHA standards that call out the “trainer qualification(s)” for those who teach on the subject matter, but the HAZWOPER standard does.  When a trainer uses the phrase HAZWOPER over and over but does not recognize this is an acronymn that stands for Hazardous Waste Operations and Emergency Response, has no emergency response background, and/or has never received...

WOW… my LOTO ppt for “Affected Personnel” that I posted earlier this week has caused quite the “back and forth” with too many people/sites.  I just assumed that we had a basic understanding of “who falls into the “affected” bucket” and “what they must know”.  Affected employees do NOT need to attend a 2-hour training course...

Many of us in the PSM/RMP arena use NFPA 51B as our Hot Work Safety Standard, rather than 1910.252(a) and with that said I thought I should update us on NFPA’s 2019 edition of 51B which includes several key improvements.  Probably the biggest changes from the 2014 edition are: the term FIRE WATCH is now officially defined, the FIRE WATCH TIME PERIOD after completion of hot work...