What does 527 CMR 33.00: Hazardous Material Process or Processing have to do with the Boston NH3 Fatality?
On March 23rd a worker at a seafood processing building/warehouse in Boston, MA was killed in a catastrophic release of anhydrous ammonia. Since then there has been much speculation as to how this tragedy occurred and whether or not the facility's refrigeration process fell under OSHA’s PSM and EPA’s RMP standards. As it appears at the time of this writing, neither OSHA’s or EPA’s process safety standard(s) applied to this refrigeration process as the process appeared to be under the 10,000 pounds threshold(s). But the state of Massachusetts has it’s own version of Process Safety standards in the way of 527 CMR 33.00: HAZARDOUS MATERIAL PROCESS OR PROCESSING and this state code does indeed cover this refrigeration process and this fatal accident. The “purpose” of 527 CMR 33.00 was to set state requirements lower than OSHA PSM thresholds and to create local fire department permit requirements for facilities engaging in the processing of certain hazardous materials. The code is based on a classification system and requires disclosure and evaluation regarding a facility’s hazardous material operations. Here's more on the state's (Massachusetts) Hazardous Material Processing Code and how it would apply to this ammonia refrigeration process: |
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