I have been given permission to OPEN up a PSM Training course in April to other clients/members.  This is a 4.5 day training course and involves field-work, so you will need to bring your PPE (Safety Glasses, Safety Boots, Hard-Hat, and FRC if you have it).  The course will be taught with a focus on Category 1 FLAMMABLE HHC, but this is such a detailed course we learn principles and RAGAGEPS that cover many of the more popular toxics.  This is NOT an introductory course, this course is designed for professionals who develop, implement, measure, and manage process safety management systems.  Here is the agenda and other details:

All workers for building trade contractors at REFINERY FACILITIES must complete a MINIMUM of 20 hours of approved advanced safety training by January 1, 2018, AND are required to do so every two (2) years thereafter. This requirement was added to the California Health and Safety Code in Section 25536.7.  To confirm that a worker is a registered apprentice, has completed a California registered apprenticeship program, or has completed the approved safety training please use:

Apprentice and Course Completion Verification search tool

Who does this apply to?

As the ballons were filled and the cake was cut, several industries got what they worked so hard to achieve... OSHA can not revise the PSM "retail" definition without going through the Public Rule Making process.  But those who take process safety and risk management seriously may be surprised to know that OSHA had already explained why they included the "retail exemption" and why they included it.  Simply put, OSHA said...

It amazes me how society, specifically lawyers and politicians, can be so collectively ignorant.  With all the change in the political winds some industries are breathing a sigh of relief regarding OSHA's efforts to redefine "retail" when it comes to the "retail exemption" found in their Process Safety Management (PSM) Standard.  For the record, I did NOT support the means in which OSHA went about changing the definition - but I fully support the change and think it is badly needed.  What amazes me is that all of these "trade groups" paid huge amounts of money to battle one of OSHA's Letter of Interpretation (LOI) that redefined "retail" as it would be applied to processes/businesses that handle highly hazardous chemicals (HHC).  Never did OSHA intend the "retail exemption" to be applied to bulk storage vessels holding tens of thousands of pounds of Highly Hazardous Chemicals, but early on in the PSM era we had courts intervening and redefining the intent of the standard (Meer Decision for flammable liquids).  And in 1995 OSHA issued their first "Letter to Regional Administrators" regarding the "retail exemption".  I do not recall any lawsuits surrounding this "interpretation" or "letter", but I may be wrong about this - I just do not remember any type of uprising about this in 1995.  But in June 2015 when OSHA decided they needed to clarify the retail definition and eliminate processes that handle tens of thousands of pounds of an HHC at any given moment from this exemption, then the uprising began because OSHA once AGAIN used the LOI process to define the exemption - JUST LIKE THEY DID IN 1995!  It seems some industry trade groups are just fine with some LOI's and not with others and the game they are playing is NOT about safety but about $$$$.

EPA received a petition dated February 28, 2017, from the RMP Coalition, representing several trade associations. The petition requests a reconsideration and request for stay for the RMP rule amendments, published January 13, 2017.  

  • On March 13, 2017, EPA's Administrator convened a proceeding for reconsideration of the RMP rule amendments.  
  • On March 16, 2017, EPA published a final rule that provides a three-month (90-day) administrative stay of the effective date of the RMP rule amendments, delaying the effective date of the final rule to June 19, 2017.

Incident Overview

738 lbs of Cl2 released from T-103, the Nash compressor seals, and leaking gasket on the suction piping at the Nash compressor.

 

Event Time line:

 
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