Much like OSHA's Letter of Interpretation, EPA has a series of "Frequently Asked Questions (FAQ)" in regards to their Risk Management Plan rule. Recently EPA answered a question regarding their take on "co-location" in which a tank with 1,000,000 pounds of toluene diisocyanate (TDI), which is covered under the RMP rule, but not under OSHA PSM. Considered by itself, the TDI would be Program 2 for EPA. The tank, however, is close to equipment that has chlorine above the applicable threshold and is subject to OSHA PSM and Program 3. Should the TDI tank be considered part of the same process as the equipment containing the chlorine? How does this affect the program level? EPA's Response is...
OSHA's new Walking-Working Surfaces and Personal Protective Equipment (Fall Protection Systems) and "hoist areas"
With OSHA's new Walking-Working Surfaces and Personal Protective Equipment (Fall Protection Systems) standard comes some new requirements for protecting workers in "hoist areas". Paragraph (b)(2) establishes fall protection requirements for workers who work in "hoist areas" that are four (4) feet or more above a lower level. The final rule defines a “hoist area” as an elevated access opening to a walking-working surface through which equipment or materials are loaded or received (final § 1910.21(b)). Paragraph (b)(2)(i) requires employers to protect workers in hoist areas from falls by:
With OSHA's new Walking-Working Surfaces and Personal Protective Equipment (Fall Protection Systems) standard comes some clarification as to when "stairs" must be provided vs. using a ladder. In the new standard, paragraphs (b)(7) through (9) specify when and where employers MUST provide standard stairs, and under what conditions employers may use spiral, ship, or alternating tread-type stairs. OSHA has simplified and reorganized the existing rule (§ 1910.24(b)) to make the requirements clearer and easier to understand. The old standard, 1910.24(b), was pretty clear, yet often over looked; this new standard states:
OSHA's new Fall Protection standard for General Industry has a lot of MAJOR changes (for the better!) that we will be dealing with over the next several years (up to 20 years for some). One that caught my eye was the new requirements for our maintenance personnel who may be doing work on low-sloped roofs (defined as a roof having a slope less than or equal to 4 in 12 (vertical to horizontal). Final paragraph (b)(13) is a new provision that establishes fall protection requirements when employees perform work on low-slope roofs. OSHA is adding this provision to make the general industry standard more consistent with the construction fall protection standard, which includes a provision addressing roofing work performed on low-slope roofs (§1926.501(b)(10)). Under paragraph (b)(13), the type of fall protection measures employers MUST use on low-slope roofs depends upon the distance they work from the roof edge. The final rule divides work on low-slope roofs into three (3) zones:
OSHA's Walking-Working Surfaces and Personal Protective Equipment (Fall Protection Systems) standard has arrived
Tomorrow OSHA will publish their new standard Walking-Working Surfaces and Personal Protective Equipment (Fall Protection Systems) in the Federal Register. This means that 60 days later (January 17, 2017), the standard will be EFFECTIVE, with some provisions having delayed enforcement dates. This rule, in the making since the 1990's, will essentially change the way FALL PROTECTION in general industry workplaces will be managed and the BIGGEST change will come to FIXED LADDERS over the next 2 years and 20 years. The new rule will FINALLY CLARIFY (beyond question) that workers must be protected from fall hazards along unprotected sides or edges that are at least 4 feet above a lower level (NOT 6' like in the construction industry!). The final rule revises and updates the requirements in the general industry WalkingWorking Surfaces standards (29 CFR part 1910, subpart D), including requirements for ladders, stairs, dockboards, and fall and falling object protection; and it adds new requirements on the design, performance, and use of personal fall protection systems (29 CFR part 1910, subpart I). The final rule also makes conforming changes to other standards in part 1910 that reference requirements in subparts D and I. Under the final rule, employers may choose from the following fall protection options:
As you have figured out I am all about having a "safety process" rather than a bunch of "safety programs" and one thing I learn in my Six Sigma days is that a "safety process" MUST function exactly like our quality processes to be as successful. This means we HAVE TO continually "sample" our safety process, just like QC is pulling samples from the manufacturing process. OSHA recently provided a guide "The Use of Metrics in Process Safety Management (PSM) Facilities" to help those who are interested in establishing some "leading indicators" within their safety process. I have also received dozens of e-mails requesting more help with this effort and thought I would share one of my favorite resources on the topic from our friends across the pond - UK's Health and Safety Executive. They have a guide that is a bit more detailed, Developing process safety indicators, A step-by-step guide for chemical and major hazard industries. This guidance is aimed at senior managers and safety professionals within major hazard organizations that wish to develop performance indicators to give improved assurance that major hazard risks are under control. Here are the guide's six basic steps to setting up process indicators measurement system...
This month we saw CAL-OSHA issue citations to a roofing company after two of its employees were literally blown off an asphalt tanker and ten (10) feet to the ground. Both workers sustained serious burns to large portions of their bodies. But after hearing all the comments about "safety is just common sense" I wonder how many professionals, including safety professionals, actually know that an asphalt tanker and kettles can and most often do contain a flammable atmopshere? One fact we do know, at least two workers and their supervisor were NOT aware of this hazard, as the two employees standing on top of a tanker truck were attempting to turn the truck’s discharge pipe to face another direction and their supervisor instructed them to heat the pipe with a propane torch in order to loosen it. The tanker was half-filled with hot liquid asphalt meaning there was plenty of vapor space in the tanker, coupled with the fact that heated liquid asphalt releases flammable vapors made for the perfect storm.
Each year about this time I get at least one phone call from a member/client about their annual "holiday inspection"; trust me when I say the term "holiday" has absolutely no relation to the Thanksgiving or Christmas holidays! However, their CMMS has spit out a work order that calls for a piping circuit to be inspected and the inspection is called a "holiday inspection". This has gotten to the point that we now will make sure that any holiday inspections are not scheduled for November/December time frame. So then what is a "holiday inspection"?
One of my all time favorite, and most reliable, sources of safety information is the FM Global Data Sheet library. And as I have said for several years now, EVERYONE can get FREE access to this library. If you work for a company that does not want to spend the money on published safety standards and you need to improve your programs and training, this library is a MUST have! Recently FM Global revised their Hot Work Data Sheet to include the following changes:
Respondent owned and operated a chemical manufacturing facility that produces anhydrous ammonia at a quantity of approximately 1,500 tons per day. The produced ammonia is used on site for the production of granulated fertilizers. Ammonia (anhydrous) is identified at 40 C.F.R. Part 68.130 as a toxic regulated substance with a threshold quantity of 10,000 pounds. Based on the quantity of regulated substances present at the facility, the facility's NAICS code, and an evaluation of off-site receptors, the covered processes at Respondent's facility are subject to Program 3 of the RMP regulations, 40 C.P.R.§§ 68.65-87. On November 5, 2015, Respondent reported a release of 5,995 pounds of anhydrous ammonia to the National Response Center, the XXXXXX Parish EOC, and the Louisiana State Police. The release occurred during an emergency shutdown process of a section of the ammonia plant during a plant upset caused by the mechanical failure of an upstream pump. Delay in initiating written emergency shutdown procedures caused the pressure to increase in the 116-P refrigeration vessel, which vented ammonia into the atmosphere through a pressure relief valve.
Yesterday morning around 3:30 am, hazmat crews detonated explosives and ignited the flammable contents of two tank cars, one was propane and one was butane, involved in a train derailment in MN. The explosions were designed to pierce the hulls of two cars, one carrying propane, the other butane. Incident Command determined that the "vent and burn" procedure was the only option after determining there was no other way to safely recover the flammable pressurized gas remaining in the LP car damaged in the derailment, and no way to access the scene to pump off the butane car. If you have never seen a “vent and burn” you can see videos of this technique Here (Transport CA Training Video) and Here (2012 I-10 V&B).
I am teaching another 1-Day Course for ASSE
Intro to Process Safety Management
February 13, 2017
The Rio, Las Vegas, NV
My Friend Jonathan Zimmerman and I are presenting at ASSE's Safety 2017
Topic: Safe Work Permit Management System
Day and Time to be posted later.
I am also working on details to do a
POST conference PSM course in CO as well.
Details to be posted later.
an unpaid endorsement
an unpaid endorsement
an unpaid endorsement
an unpaid endorsement