For years now OSHA and EPA have taken similar approaches to how they view DOT containers (Tank Trucks and Railcars) when they are connected to a process. Both agencies have stated that as long as the motive power (e.g. tractor or locomotive) remains in place then the unloading falls under DOT and thus the content in the DOT container does NOT have to be counted towards our Threshold Determination. However, "drop the trailer/railcar" then we have to view the DOT container as a process vessel/storage vessel and consider its contents towards our Threshold Determination. Keep in mind that a single 55/90 Ton Railcar of Chlorine sitting on our property is in and of itself a "covered process" regardless of where it sits; however, co-locating it in near proximity may make the RCar part of the existing covered process. But recently some OSHA state plans have posed new views on this DOT application towards PSM/RMP...
OSHA has issued two (2) citations to a construction contractor for $14,000 after an employee died within a permit-required confined space on 12/7/2015. The company is contesting the citations. The citations involved:
REVISED Safety Advisory: Emergency Discharge Control Equipment Installation on Cargo Tank Motor Vehicles Resulting in the Potential Loss of Vehicle Control (FMCSA 2016)
The Federal Motor Carrier Safety Administration (FMCSA), in conjunction with the Pipeline and Hazardous Materials Safety Administration (PHMSA), is issuing this safety advisory to provide notice of emergency discharge control equipment connected to and installed on cargo tank motor vehicles, which when improperly installed, do not operate correctly and can result in total loss of power to the cargo tank motor vehicle. This revised safety advisory updates and replaces the
HAZMAT Safety Advisory: Immediate re-inspection and retesting of certain cargo tank motor vehicles required (FMCSA 2016)
Federal Motor Carrier Safety Administration (FMCSA) is issuing this safety advisory to provide notice to owners and operators of certain cargo tanks that they have been improperly inspected and tested, and must be re-inspected and retested before being used in Hazardous Materials specification tank service. The tanks in question were tested by H&W Tank Testing, CT#8083, Ohatchee, Alabama, and Christopher Humphries, CT#13131, Jacksonville, Alabama. Cargo tanks that have been inspected and/or tested by either company from April 2011 through March 2016, must be re-inspected and/or retested in accordance with 49 CFR § 180.407 immediately by a cargo tank facility registered with FMCSA.
The Federal Motor Carrier Safety Administration (FMCSA) is issuing this safety advisory concerning pressure relief devices (PRD) that were not manufactured or intended for use on cargo tank motor vehicles. PRDs are an integral part of the safety mechanisms for U.S. Department of Transportation (DOT) specification cargo tank motor vehicles and are vital to ensuring the safety of hazardous materials transportation by highway.
The Ohio Department of Commerce, Division of State Fire Marshal (SFM) has recently completed training modules highlighting significant changes from the 2007 version to the 2011 version of the Ohio Fire Code (OFC). You can access the modules via links on the SFM’s website “2011 Ohio Fire Code Training Modules”. There you will find links to the International Code Council’s Campus (ICC) (where the modules are housed), a tutorial regarding how to create an account with the ICC and access the 2011 Ohio Fire Code Training Modules, and how to receive a certificate for completing the courses. There is also a technical support phone number for the ICC, and contact information for the SFM where you can provide feedback regarding the modules.
The Department of Industrial Relations (DIR), the Governor’s Office of Emergency Services (Cal OES) and the California Environmental Protection Agency (CalEPA) today announced a landmark set of regulations to strengthen workplace and environmental safety at oil refineries across the state. The regulatory proposals are intended to make California refineries safer both for workers and surrounding communities. The two regulations implement key recommendations of the Governor’s Interagency Working Group on Refinery Safety, and are the result of a multi-year effort, including extensive consultation with workers, industry, NGOs, and communities, following a serious chemical release and fire at Chevron’s Richmond oil refinery in August 2012. The proposal includes two complementary regulations...
As I have said in the past, the National Board publishes a FREE magazine, The Bulletin, each quarter that almost always contains information that we can use in our daily management of chemical processes. The best part of these FREE articles are they come from a VERY RELIABLE source and are written in such a manner that we do not have to be Professional Engineers (PE) to understand them! This edition has an outstanding article regarding the Inservice Testing for Pressure Relief Valves.
FY 2016 U.S. Chemical Safety and Hazard Investigation Board Management Challenges (EPA Office of Inspector General)
Attention to CSB management challenges could result in stronger results and protection for the public, and increased confidence in management integrity and accountability. Based on our continuous audit work, CSB public hearings, congressional hearings and CSB board meetings, EPA's IG identified three (3) management challenges and one internal control weakness related to operational controls. The newly confirmed Chairperson has implemented initiatives to improve employee morale by creating an environment to encourage open communication.
Respondent operates a meat processing facility that uses 24,300 pounds of ammonia as its refrigerant. Respondent has one RMProgram level 3 covered process, an ammonia refrigeration process, which stores or otherwise uses a toxic chemical in an amount exceeding its applicable threshold of 10,000. During calendar year 2014, EPA opened an RMProgram compliance monitoring investigation to determine Respondent's compliance with 40 C.F.R. Part 68. As part of this investigation, the EPA conducted an onsite inspection of RMProgram related records on May 22, 2014. The focus of the onsite inspection was to assess the Respondent's compliance with RMProgram requirements for its covered process.