If an owner of a stationary source leases propane tanks from a gas supplier, who is responsible for preparing and submitting the risk management plan (RMP) addressing the propane tanks? … HomeRead More »

 I run a wastewater treatment plant that is subject to the risk management program regulations in 40 CFR Part 68 for a covered process containing chlorine. A chlorine scrubber system at the plant is designed to prevent any possible releases from reaching a toxic endpoint offsite. How does this active mitigation system affect my selection and analysis of an alternative release scenario? …...

The Risk Management Program regulations require owners and operators of stationary sources to coordinate their response needs annually, or more frequently if necessary, with local emergency planning and response organizations (40 CFR §68.93(a)). Are stationary sources responsible for determining if coordination activities should occur more often than annually? … HomeRead More »

Does the owner or operator have to maintain a written copy of the RMP on site at the stationary source? … HomeRead More »

To analyze the worst-case release scenario required as part of the hazard assessment at 40 CFR Part 68, Subpart B, the worst-case release quantity is identified as the greatest amount held in a single vessel or pipe, taking into account administrative controls that limit the maximum quantity (40 CFR §68.25(b)). Are mechanical controls such as alarms considered administrative controls and therefore...

Does the “greatest distance to an endpoint” refer to the greatest total distance from the process (e.g., vessel or pipeline) or to the distance beyond the stationary source boundary? … HomeRead More »

How close must a stationary source be to a weather station in order for that station’s data to be applicable to the stationary source? … HomeRead More »

The implementing agency will, according to the regulations at 40 CFR §68.220(b), select stationary sources for audits based on any of the following seven (7) criteria: … HomeRead More »

Competence is defined in ISO 45001:2018, 3.23, as “the ability to apply knowledge and skills to achieve intended results”. Competence enables a person or organization to act effectively in a job or situation. It is acquired through training, education, experience, or a combination of these, as determined by the organization. Workers whose activities affect or can affect an organization’s OH&S performance,...

As we have discussed, OSHA does not have a “flammable gas” standard for those flammable gases outside the scope of its Liquefied Petroleum Gas (LPG) standard 1910.110.  So in most of my work with flammable gases, I will use 1910.110 or NFPA 58 as my RAGAGEP.  I do this as many facilities already have some fundamental understanding of LPG hazards.  This all starts with “siting”...

It is difficult for engineers to change human nature and therefore, instead of trying to persuade people not to make errors, we should accept people as we find them and try to remove opportunities for error by changing the work situation — that is, the plant or equipment design or the method of working. Alternatively, we can mitigate the consequences of error or provide opportunities for recovery....

I have been surprised at our profession’s lack of basic understanding regarding pressure and vacuum.  I think most people of the general public have no idea that we live under 14.7 pounds of pressure per square inch on our bodies.  We say this is what it is at SEA LEVEL, which means a lot.  As with the recent catastrophic implosion of the submersible, it was well BELOW “sea...