The plan must provide for advanced first aid support trained personnel. These personnel must be qualified Basic Life Support (BLS) personnel or better-trained personnel. BLS refers to a unique group of trained individuals (e.g., EMTs) who have received an established level of specialized training that exceeds basic first aid skills such as control of bleeding and cardiopulmonary resuscitation (CPR)....

The ERP must contain provisions for decontamination of emergency responders leaving the exclusion zone. Individuals who will assist the responders as they leave the exclusion area must be trained in decontamination procedures. These individuals must wear PPE at the same level or one level below that worn by the emergency responders they are supporting, as appropriate to the hazards. Decontamination...

All employees that are not trained in emergency response and who will not be needed during the response operation should be evacuated from the exclusion and decontamination zones. This aspect of the ERP should be in compliance with 1910.38 as described in Section XII.A.2. CSHOs must use 1910.38 as a model to evaluate the employer’s “evacuation routes and procedures.” The CSHO shall...

Areas surrounding the danger area must be controlled during emergencies by prohibiting unauthorized personnel from entering the emergency release area. Methods of excluding areas and defining various zones need to be addressed in the ERP. … HomeRead More »

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 who 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 promptly....

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.” … HomeRead More »

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. … HomeRead More »

We see a lot of great efforts on emergency response plans, but so many times, folks 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  … HomeRead More »

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...