One of the biggest hurdles for an organization entering OSHA’s and EPA’s process safety standards is that some old OSHA standards are just NOT adequate based on the new level of risks. This is most noticeable are with flammable liquid processes. Take, for example, 1910.106, OSHA’s Flammable liquids standard. It is “OK” for businesses that use flammable liquids in smaller quantities, but it falls short of providing ample safeguards when a process handles over 10,000 pounds of flammable liquids. This is why OSHA/EPA requires the facility to adopt a Recognized and Generally Accepted Good Engineering Practice (RAGAGEP) to manage the hazards/risks associated with these bulk quantities of flammable liquids, such as NFPA 30.
Did you know that 1910.106 was based on a 1960’s edition of NFPA 30? The same could be said for…
1910.307, OSHA’s Hazardous (classified) Locations standard. Just like 1910.106, it is a nice start to classifying areas where flammables are stored and handled; but “processing” flammable liquids and gases raise the risks, so the facility needs to use NFPA 497 and NFPA 70 to better establish their classified areas.
So 1910.106 and .307 have their place in NON-PSM/RMP covered processes, but once a process passes the 10,000-pound threshold, the level of risks calls for better RAGAGEP’s be used to control those risks.