The safe places of refuge (out-of-doors or shelter-in-place) should be the areas where an accounting of all employees will be performed. This can be critically important for identifying individuals that did not get out, estimating where they may be, and initiating any rescue operation. Information on safe places of refuge must be given to the emergency response organization or emergency response team...

This is by FAR the most misunderstood element of all! The ERP must define the types of releases that could potentially require an emergency response and should define what types of releases would not be an emergency, or, in other words, what may be handled as an “incidental release”. The ERP should include an inventory of the hazardous substances found on site, the manner in which...

Personnel roles must be clearly defined in the ERP. One method of doing this is to list job titles and describe their projected roles in emergency response operations. Although specific HAZWOPER titles are not required, employees should be designated to assume duties that parallel 1910.120(q)(6) and must be trained accordingly. Lines of authority must also be made clear in the ERP. The senior...

We see a lot of great efforts on emergency response plans, but so many times folks just do not know the details OSHA will be looking for. Here are the required sections/information for your ERP and the details required.   (q)(2)(i) Pre-emergency Planning and Coordination    1) Does the plan address coordination with outside emergency response organizations?    2) Have employers...

Most of the facilities we work at have a mechanical integrity program for the process equipment. Most have a Work Order system for their preventative maintenance program. This system kicks out a work order for the PM(s) due. Most facilities track the closure rates of the PM W.O.’s. My tip… Add ALL of your emergency response equipment to this system. Items such as: sprinkler annual flow...

That is PSM lingo for…when you are utilizing Risk Based Inspection (RBI) protocols and you wish to extend the inspection or PM frequencies on a piece of covered equipment, this is without a doubt a change that REQUIRES an MOC. … HomeRead More »

Following the Buncefield incident the importance of preventing loss of containment from bulk storage tanks has come to the fore. A significant factor in ensuring contained fluids are not accidentally released is the continuing mechanical integrity of the tank structure. http://www.hse.gov.uk/research/rrhtm/rr760.htm

OK, PSM requires us to evaluate our “contractors” who will be working on, in or adjacent to a covered process. OSHA’s Permit Required Confined Space Standard also comes into play during a PSM audit (see .119(f)(4)). Under the PRCS std. OSHA requires us to “evaluate” our rescue services (.146(k)(1)(i)-(ii)) using something similar to Appendix F from .146. Since I have yet...

We always get the answer…”We do not have any temporary operations,” so that does not apply to us. A good auditor will educate the site personnel by taking them out to the field and finding a bypass around a control device. Then, we will ask for the “procedure” that is used when the bypass is open and the control device is “temporarily” out of service. If you...

Often we see facilities viewing MOC and PSSR’s management systems as DUPLICATIVE efforts. There is a distinct difference between these two PSM/RMP requirements. Basically, this is how it was so explained to me by Russ Evanston, one of the founding fathers of PSM. … HomeRead More »

OSHA and EPA are now citing for not doing MOCs on personnel changes!  The debate rages on for those living in the PSM/RMP world. Just this week, a client called me to help them with an audit finding they received in a third-party audit. The auditor wrote the finding that they were not considering personnel changes in their MOC program. I too often write a similar finding when I come across situations...

Well I told you last week that I would scare the !@#$ out of a lot of you, so here it goes.  Nitrogen can be your ignition source if it is NOT applied and used properly. … HomeRead More »