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Improving the Nation’s Chemical Security Program Statistics as of May 1, 2015

  • More than 49,000 preliminary assessments were reviewed by DHS from facilities with chemicals of interest
  • 3,348 facilities are currently covered by CFATS
  • More than 3,000 facilities voluntarily removed, reduced, or modified their holdings of chemicals of interest
  • 1,890 visits to assist facilities with compliance
  • 3,063 Security Plans authorized
  • 2,276 Authorization Inspections conducted
  • 1,782 Security Plans approved following an on-site inspection

This decision covers several interesting items and sets a HUGE precedent for RESPONSIBILITY of PHA and Audit items from the PREVIOUS owners PHAs and Audits.  The decision CONFIRMED that "utilities" within the process, in this case a "positive pressure unit" on a control room ventilation system, is a piece of COVERED EQUIPMENT.  It also establishes minimums for when an employer uses "alternatives" to labeling each container of hazardous chemicals, being that the said containers were process vessels.  The commission vacated two citations, which the machine guarding item involving an unguarded horizontal merely because OSHA could not show "exposure to the hazard" and an MOC citation since the use of steam lances was a "common occurrence at the refinery".  The item regarding the PHA and Audit items from a previous employer/owner could be a HUGE precedent for future sales of facilities that have covered processes.  Here is the case...

tank and bollardsMost everyone has seen a bollard; they may have not realized what they were seeing at the time, but most have seen one.  But this group of people who have seen one grows much smaller when we begin to ask “what makes a bollard a safety device?”  A couple of years ago I shared an engineering standard for bollards and vehicle protection.  That page has been viewed more than 200,000 times since 2012, so there must be some level of interest in these safety devices.  I lost count of the number of e-mails I received asking if the post was a “joke”, as who in their right mind would have an engineering design for a post?!?!  Well a well designed, constructed, chemical process that utilizes mobile equipment within their process battery limits… that's who!  Just last year we issued several audit findings for either the lack of or improper design of bollards protecting bulk tanks and other "critical" process equipment.  These were PSM audits… so what RAGAGEP did we reference?

 
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Stop by session 721 on

Wednesday 6/10 @ 7:45 a.m.

Process Safety Management

Enforcement Trends and Best Practices

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"Implementing a World-Class PSM Program"

Course # 910

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