April 21, 2015 MEMORANDUM FOR: REGIONAL ADMINISTRATORS THROUGH: DOROTHY DOUGHERTY Deputy Assistant Secretary FROM: THOMAS GALASSI, Director Directorate of Enforcement Programs SUBJECT: Evaluating Hazardous Levels of Accumulation Depth for Combustible Dusts   The purpose of this memorandum is to provide guidance in calculating the levels of dust accumulations that may be allowed at workplaces for...

PLEASE NOTE the LOI in which OSHA adopted EPA’s 1% rule was thrown out by the courts so I am NOT 100% sure OSHA can use the 1% rule from EPA in their evaluations of what is a covered process/HHC. Last week OSHA changed their position in how they will handle “mixtures” of those chemicals listed in 1910.119 Appendix A WITHOUT a concentration percentage listed.  OSHA rescinded...

With OSHA’s change last week in how PSM applies to “mixtures” of HHCs I have received a number of questions about “partial pressure” and what impact it can have on whether my process is covered or not?  EPA has been using “partial pressure” of 10 mm Hg for their mixture applicability rule since 1999, but there are a lot of PSM processes that are not covered...

I shot this video just before my safety training session at a safety convention this summer.  When I asked for it to be fixed, the venue manager and workers were confused because the projector had power.  When I tried to explain the issue they all of a sudden had trouble with the english language.  If we can not expect mere compliance with the most basic of electrical safety while working...

 

Yes, OSHA has rules for the use of flammable liquids in areas that are not designed as a Hazardous Location.  OSHA covers Hazardous Locations in 1910.307, but those areas that do not rise to the level of being a Hazardous Location fall under 1910.334(d) which states: … HomeRead More »

MEMORANDUM FOR: REGIONAL ADMINISTRATORS AND STATE PLAN DESIGNEES THROUGH: DOROTHY DOUGHERTYDeputy Assistant Secretary FROM: THOMAS GALASSI DirectorDirectorate of Enforcement Programs SUBJECT: Process Safety Management of Highly Hazardous Chemicalsand Covered Concentrations of Listed Appendix A Chemicals This memorandum revises OSHA’s enforcement policy on the concentration of a chemical that...

MEMORANDUM FOR: REGIONAL ADMINISTRATORS AND STATE PLAN DESIGNEES THROUGH: DOROTHY DOUGHERTYDeputy Assistant Secretary FROM: THOMAS GALASSI DirectorDirectorate of Enforcement Programs SUBJECT: RAGAGEP in Process Safety Management Enforcement This memorandum provides guidance on the enforcement of the Process Safety Management (PSM) Standard’s recognized and generally accepted good engineering...

Today the US Chemical Safety Board released a DRAFT report on a 2009 Explosion and Fire at a petroleum terminal facility.  So far, the CSB has identified “Inadequate Management of Gasoline Storage Tank Overfill Hazard” as the root cause of this accident.  I can still remember the 2005 Buncefield incident that very closely mirrors this incident in the respect that it was an OVER-FLOW...

CLICK HERE (doc) for one of the Contractor Work Permit written program that I used during my time as a Safety Manager in the chemical industry. CLICK HERE (pdf) for the Work Permit

June 2015 marks the one-year anniversary of EO 13650 – Actions to Improve Chemical Facility Safety and Security – A Shared Commitment: Report for the President. The EO Working Group has released a fact sheet on the accomplishments to date on improving chemical facility safety and security since the publishing of the Report to the President.  … HomeRead More »

This week I am teaming up with my friend and safety colleague Jonathan Zimmerman at the 2015 ASSE Conference.  I have uploaded our presentation, as well as the PSM Inspection Data that was so generously provided by some other friends who I can not mention publicly (but you know who you are and THANKS a million for all your support!).  If you’re attending Safety 2015 this week, please...