Have you ever read a RAGAGEP and wished you had been a fly on the wall in the room where a particular requirement was presented and debated amongst the committee members?  I have set on my fair share of RAGAGEP committees over the past 20 years and in almost all of muy experiences, when someone would bring an idea to the floor that was well outside any fundamental risks acceptance or engineering,...

As we continue to “dumb down” RAGAGEPs to take away OSHA/EPA’s ability to cite fundamental engineering failures found in processes handling HHC/EHS, the issue of “conflicting requirements” continues to be troubling.  As my Anhydrous Ammonia clients learned firsthand last year, with the 7th edition of CGA 2.1, the RAGAGEP has some NEW requirements for pressure testing...

The 2024 edition of the International Fire Code has a new “table” that lists several exemptions.  These exemptions come with some limitations, such as… Exempted materials and conditions listed in this table are required to comply with provisions of this code that are not based on exceeding maximum allowable quantities inSection 5003. Here are a few of the exemptions that may...

This was NOT intended to be directed at safety, but damn, if we look at all 13 through the lens of “barriers to world-class safety,” they sure do resonate. I have bolded my Top 3; which are your Top 3? 13 Brutal Truths Every Employer Needs to Know: … HomeRead More »

Both OSHA and EPA require PSM/RMP facilities to include procedures for “responding to small releases” in their Emergency Action Plans 1910.119(n) Emergency planning and response The employer shall establish and implement an emergency action plan for the entire plant in accordance with the provisions of 29 CFR 1910.38. In addition, the emergency action plan shall include procedures for...

This is in my community, and I just had to share.   The back story is… Recently, a child was struck crossing the street at this intersection.  The child was “treated and released” at a local ER and will fully recover (Physically, mentally, not so sure).  Neighbors had been complaining to the police about the increased traffic at this intersection due to a new subdivision...

A loss of containment and subsequent release of fluids can cause adverse consequences (i.e., impact safety, health, and environment, cause production losses, andincur maintenance and reconstruction costs). The risk analysis should consider the nature of the hazards and ensure that appropriate factors are considered for the equipment items being assessed. Flammable Events (Fire and Explosion) …...

29 CFR 1910.119(f)(1) The employer shall develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information. … HomeRead More »

I am never disappointed in social media’s ability to tell me daily just how bad traditional safety practices are. I am also wondering if there is an aspect of business management that gets beat up and denounced more than safety. It seems we are never without so many new options/directions in safety, and unfortunately, many of these new options and directions claim to be the silver bullet –...

In process safety circles, the word “remote” is found in several codes/standards. In OSHA’s Process Safety Management standard, we find it used in the Normally Unoccupied and Remote Facility (NURF) exemption (1910.119(a)(2)(iii). OSHA did us a favor by officially defining this phrase; however, they have never QUANTIFIED it. Normally unoccupied remote facility means a facility which...

The following changes will be made to Guide 115 in the 2024 edition of the ERG: … HomeRead More »

Respondent owns and operates a cheese manufacturing facility. On March 22, 2022, EPA performed an inspection of the Facility to evaluate compliance with CERCLA Section 103, EPCRA Sections 304-312, and CAA Section 112(r). Based upon the information gathered during the Inspection and subsequent investigation, EPA determined that Respondent violated certain provisions of CERCLA, EPCRA, and the CAA. ALLEGED...