It has taken me 25 years to diagnose it, but I have finally establish the "Delusional Safety Syndrome" (DSS). It is the only mental illness known at this time that is actually contagious. It is spread by close contact with an infected person. It can lie dormant for years and the infected person can spread the disease before they even recognize they are ill. Some symptoms include:
This is a follow up to my July 2013 article “Making the case my PSM/RMP covered process complies with RAGAGEPs (Piping)”. With OSHA’s recent memo on “RAGAGEP in Process Safety Management Enforcement” I have received renewed request to explain how a facility can demonstrate their vessels/tanks comply with RAGAGEP(s). Here it goes:
Are you providing a copy of 1910.134 Appednix D to each employee who wears a filtering facepieces (dust masks) on a “voluntary basis”? Are you controlling these filtering facepieces (dust masks) so that ONLY employees who have been provided with a copy of Appendix D have access to these filtering facepieces (dust masks)? For the past 15 or so years I, and I know of many other safety pro’s, have apparently been in error with regards to our obligation(s) when employees wear filtering facepieces (dust masks) on a “voluntary basis”. I was under the impression that the exception found in 1910.134(c)(2)(ii) exempted the need to have any kind of respiratory protection program if the ONLY respirator used on site involved the voluntary use of filtering facepieces (dust masks). This is really concerning to me, as I have had dozens of discussions with current and retired OSHA personnel, some as high as Area Director, and it seems that even some OSHA personnel may find this position confusing. Here's why...
As part of their Industrial Safety Ordinance Contra Costa County, CA developed a VERY NICE safety culture survey. It is a requirement for CalARP facilities, but just a GREAT RESOURCE for the rest of us. Check it out Attachment E: Safety Culture Assessment (PDF). You may have some work to do to get it in a manageable format, but the content is WORLD-CLASS and it is FREE!
Industrial Safety Ordinance
Industrial Safety Ordinance
Industrial Safety Ordinance
When it comes to EPA's Risk Management Plan rule, the state of California made significant modifications to the RMP rule. Basically, California replaced the Risk Management and Prevention Program with the California Accidental Release Prevention (CalARP) Program on January 1, 1997. The CalARP Program is very similar to the EPA's Risk Management Program with the following differences:
Process or storage vessels and pipe systems that contain ignitable ranges of oxygen and flammable vapors are susceptible to catastrophic explosions. If the oxygen and vapor mixture is ignited by sparks, arcs, friction, compression or other heat sources, the expanding flame front may cause significant injuries and damage. One method of lessening the likelihood of a flash fire is by the installation of a flame arrestor in the equipment or on the end of a vent or process line. Flame arrestors are used in many industries, including refining, oil exploration and production, pharmaceutical, chemical, petrochemical, pulp and paper, sewage treatment, landfills, mining, power generation, and bulk liquids transportation.
Here is the presentation that Jim Lay, P.E., from OSHA's Office of Chemical Process Safety & Enforcement Initiatives did last week @ ASSE's Annual Conference. He did this presentation the same day OSHA rolled out their new enforcement policies on chemical mixtures and RAGAGEP enforcement. The presentation covers: RAGAGEP Background, Early recognition of RAGAGEP, RAGAGEP in OSHA’s PSM standard, New RAGAGEP Enforcement Guidance. PSM expects employers to: 1) determine and document the codes, standards, and practices they will follow, and then, 2) Implement and follow those codes, standards, and practices.
“Say what you’ll do, and do what you say!”
The purpose of this memorandum is to provide guidance in calculating the levels of dust accumulations that may be allowed at workplaces for combustible dusts with bulk densities less than 75 lb/ft3. The guidance provided in this memorandum supplements the dust accumulation guidance provided in several sections of CPL 03-00-008, Combustible Dust National Emphasis Program (Reissued), including IX.E.3.c and d; IX.E.8; and IX.E.9.c and d.
Several sections of CPL 03-00-008, Combustible Dust National Emphasis Program (Reissued), reference 1/32 inch dust accumulation levels. This accumulation thickness is based on certain assumptions, including uniformity of the dust layer covering the surfaces and a bulk density of 75 lb/ ft3 of the material. NFPA 654 (2013) allows the dust accumulation level to exceed the layer depth criteria of 1/32 inch according to the following equation for materials with bulk density less than 75 lb/ft3:
How could OSHA’s move to EPA’s “1% rule” for mixtures change at facilities handling OSHA PSM HHC mixtures?
Last week OSHA changed their position in how they will handle “mixtures” of those chemicals listed in 1910.119 Appendix A WITHOUT a concentration percentage listed. OSHA rescinded all prior policy documents, letters of interpretation, and memoranda related to the maximum “commercial grade” or pure (chemical) grade policy in favor of a one (1) percent test similar to that adopted by EPA in regards to their RMP rule (e.g. EPA’s “1% rule”). Yes, using EPA’s “1% Rule” for both PSM and RMP does make things simpler for everyone, but boy-oh-boy does it have some potential challenges for industry. Lets examine some of the implications this change could have…