A lot of PSM/RMP covered processes utilize ventialtion as an engineering control within the process.  And if this is the case, then OSHA and EPA require the facility to have supporting documentation to show that the ventilation will do what it it intended to do. … HomeRead More »

Some companies develop an elaborate generic energy control procedure and supplement the generic procedure with checklists or appendices to address various distinct machinery and equipment in their facilities. This type of procedure and those described above may be considered a single energy control procedure (instead of multiple procedures) for inspection purposes if all of the criteria contained in...

OSHA says we are to have machine-specific LOTO procedures (note that there is an exception to this requirement, but in my scenario, it is not relative). In these procedures, we have to identify the following: the types of energy, their magnitudes, the means/methods to isolate and the means/methods to verify zero energy state (ZES) for each source Suppose you or I go out to do our periodic LOTO inspection,...

No hunman and no organization is perfect!  Although we should strive for perfection in all aspects of business (Production, Quality, Cost Control, and EHS), we often mis-step or possible loose our way altogether.  But how bad do things have to get before it is a REAL PROBLEM? … HomeRead More »

Many THANKS to my NEW {amp}amp; RENEWING Corporate Partners in Safety! since 2007 since 2011 since 2009 since 2/11 2011 Fatality Tracker Electrical 5 (2010 = 90) (2009 = 100) Forklift/Manlift Mobile Equipment{amp}nbsp; 27 (2010 = 110) (2009=88) Mining 43 (2010 = 480)...

I continue to see facilities struggle with the emergency shutdown SOP requirements and how it is all suppose to flow and fit into the daily operations.  In this post I will try and lay out a flow to help make sense of these PSM/RMP requirements.  I am hopeful you can learn from my mistakes, as I have learned this the hard way from many OSHA inspections and accident investigations. …...

We do not see these types of failures often, but when we do it can almost always be traced back to human error.  Back in 2008, a tube and shell heat exchanger catastrophically failed when workers accidentally closed two different valves at two different times between the vessel and its relief valve. On June 10, 2008, operators closed an isolation valve between the heat exchanger shell (ammonia...

Does the title make you scratch your head? I usually get some strange looks when working with a client who is trying to understand what the PSM compliance cycle looks like. To start with, let’s look at what OSHA/EPA requires in our operating procedures: 1910.119(f)(1)(ii) Operating limits 1910.119(f)(1)(ii)(A) Consequences of deviation 1910.119(f)(1)(ii)(B) Steps required to correct or avoid...

If your PSM/RMP covered process contains a flammable liquid, 1910.106 has provided us with some regulatory facility siting requirements that we can quickly inspect to ensure we meet the minimum compliance distances. If you have liquefied petroleum gases within your facility, 1910.110 provides some basic siting requirements that should be met to have an argument that the propane will not impact your...

Many chemical processes that are covered under OSHA’s PSM and EPA RMP rules utilize one of the most popular forms of passive mitigation ever known…Diking.  However, on the other hand, many of the facilities have not included their dikes in their Process Safety Information (PSI) or their Mechanical Integrity Programs (MIP). … HomeRead More »

I had an interesting dissertation given to me on how to calculate “frequency” when analyzing a PHA scenario during a recent PHA. Although it sounded logical, it was completely off base and thus would have shown the facility at very low risk for all their scenarios. This is something we see from time to time so I thought I would provide my two cents on the matter. 1) PHA participants should...

Since the great recession of 2008 -2010 we have seen an increase in the used equipment market.  This is due to so many businesses going under and auctioning off their equipment and the remaining businesses needing to find ways to save $. … HomeRead More »