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One of the most often asked questions in my Process Safety training courses is... "What do you mean when you say Layers of Protection?"  So I have made this very simplified powerpoint presentation to provide a visual of how "Layers of Protection" are effective and how they BECOME INEFFECTIVE.  This safety principle is most often mentioned in process safety circles, but in reality, it applies to our traditional health and safety models as well.  Even when we discuss the "Hierarchy of Controls" we are discussing our layers of protection, as in many cases we NEVER rely on one level of control to minimize risks.  For example...

 

 

 

 

Both OSHA's and EPA's process safety standards have a requirement called "Design codes and standards employed", but why do the standards require this and what should it look like in our Process Safety Information management system?  In a review of our past audits, we almost always find gaps in the facility's list of Design codes and standards employed. 

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An analyzer engineer was fatality injured when the engineer removed the cover on an explosion-proof enclosure as part of a routine task. The threaded cover weighing ~12 lbs. and measuring 14 inches in diameter was forcefully propelled from the enclosure as the engineer unscrewed it inflicting a fatal head injury. The force was caused by pressure inside the enclosure from leaking sample gas or instrument air components. The enclosure was not equipped with an external indicator to determine the pressure inside the enclosure and had no means to relieve internal pressure.

CLICK HERE (pdf) for the Alert

Note: Images are representative only.

The Environmental Protection Agency (EPA) is delaying the effective date of the Risk Management Program Amendments for an additional 20 months, to allow EPA to conduct a reconsideration proceeding and to consider other issues that may benefit from additional comment. The new effective date of the rule is FEBRUARY 19, 2019. The Risk Management Program Amendments were published in the Federal Register on January 13, 2017. On January 26, 2017 and on March 16, 2017, EPA published two documents in the Federal Register that delayed the effective date of the amendments until June 19, 2017. The EPA proposed in an April 3, 2017 Federal Register action to further delay the effective date until February 19, 2019 and held a public hearing on April 19, 2017. This action allows the Agency time to consider petitions for reconsideration of the Risk Management Program Amendments and take further regulatory action, as appropriate, which could include proposing and finalizing a rule to revise or rescind these amendments.  CLICK HERE for the unpublished announcement.  It is scheduled for publication this week if you want to wait for the government release.

The Department of Labor and Industries cited a refinery for forty-five alleged violations of various Washington Administrative Code sections assessing a penalty of $2,393,000 as a result of an explosion and fire that occurred at the refinery on the early morning of April 2, 2010 that resulted in seven fatalities. The refiner contends that it did not violate any of the code sections and that the explosion and fire was caused by something unrelated to its failure to follow these rules. The Department has failed to show by a preponderance of the evidence that the refinery committed any of the alleged violations and the Corrective Notice of Redetermination is VACATED.

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This week the USDOL-OSHA, Directorate of Enforcement Programs, Office of Chemical Process Safety and Enforcement Initiatives team (Jeff Wanko, Jim Lay and Mike Marshall) presented an update on OSHA's PSM Activities.  This is the first such kind of update in over a year so it has some interesting DATA and updates to OSHA CHEM NEP approach. I have listed some of the highlights below, but if you want to download their .ppt just click on the image to the left.

 

Here is the update by the numbers...

 

 

 

 
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Training Course: 

"Safety" for

Process Safety Managers 

September 18-22, 2017
Cincinnati, OH

CLICK HERE for more

 

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