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Not a trick question, but boy do we get “the look” when we ask the question just as it is written in 68.79 and .119(o). What does OSHA and EPA mean by certifying an audit? Who does this certification? Is this a formal exercise of certifying? Why did OSHA/EPA use this term in the standard? Here is my take…
I recently participated in a PHA for a large flammable liquids process and during the "facility siting" portion of the PHA we took a detailed tour of the process. During which, several significant "impact" hazards were identified. Of course the long-time engineering manager (40 plus years of fine service at the facility) quickly went to the "its been that way for 50+ years and no one has hit the pipe/pipe support or dropped a load on the pipe/pipe support". So the question is... How much "safety credit" should we give based on a 50 year run of no damage/incidents when we can plainly see that the scenario has a high potential?
This Alert is intended to inform the industry that companies must take responsibility to prevent accidental releases of dangerous chemicals like anhydrous ammonia through compliance with CAA’s Chemical Accident Prevention Program. Evidence gathered by the U.S. Environmental Protection Agency (EPA) indicates that some refrigeration facilities may be failing to properly manage hazardous chemicals, including anhydrous ammonia, as required by the Clean Air Act (CAA) Section 112(r). This Alert is intended to inform the industry that companies must take responsibility to prevent accidental releases of dangerous chemicals like anhydrous ammonia through compliance with CAA’s Chemical Accident Prevention Program.
Recently EPA issued a Consent Decree in response to a company that had two (2) facilities inspected under the Risk Management Plan Rule (40 CFR Part 68). The document was much like the many others I have posted here; however, this agreement contained a lengthy audit plan that EPA and the company agreed to as part of the resolution of the inspections. This material could be viewed as an inside look at what EPA expects from 3-year audits. I thought it was worth passing on, as we still see way too many 3-year audits being done that do not even scratch the surface! It should be noted, that EPA took a two prong approach with this audit plan, as this company managed RMP from a corporate office with "pass down" to the two facilities in this agreement. The audit plan included an audit of the Corporate Office for its role in RMP compliance, as well the two facilities involved in these inspections. This company has more than these two facilities involved in these inspections. Here is EPA's audit plan...