Much like OSHA's Letter of Interpretation, EPA has a series of "Frequently Asked Questions (FAQ)" in regards to their Risk Management Plan rule.  Recently EPA answered a question regarding their take on "co-location" in which a tank with 1,000,000 pounds of toluene diisocyanate (TDI), which is covered under the RMP rule, but not under OSHA PSM. Considered by itself, the TDI would be Program 2 for EPA. The tank, however, is close to equipment that has chlorine above the applicable threshold and is subject to OSHA PSM and Program 3. Should the TDI tank be considered part of the same process as the equipment containing the chlorine? How does this affect the program level?  EPA's Response is...

Each year about this time I get at least one phone call from a member/client about their annual "holiday inspection"; trust me when I say the term "holiday" has absolutely no relation to the Thanksgiving or Christmas holidays!  However, their CMMS has spit out a work order that calls for a piping circuit to be inspected and the inspection is called a "holiday inspection".  This has gotten to the point that we now will make sure that any holiday inspections are not scheduled for November/December time frame.  So then what is a "holiday inspection"?

One of my all time favorite, and most reliable, sources of safety information is the FM Global Data Sheet library.  And as I have said for several years now, EVERYONE can get FREE access to this library.  If you work for a company that does not want to spend the money on published safety standards and you need to improve your programs and training, this library is a MUST have!  Recently FM Global revised their Hot Work Data Sheet to include the following changes:

How many have noticed that OSHA's listing of Sulfur Dioxide in 1910.119 Appendix A has a special designation?  

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So what does the "liquid" designation mean?

Ohio EPA has offered up three (3) scenarios to walk us through the thought process of establishing the "program level" for our RMP covered process(s).  These are actually quite good examples...

What Program?

Recently in the Pacific North West, Coast Guard marine inspectors experienced two different circumstances involving the alarm and control system of steering gears onboard relatively new vessels. Although neither event resulted in a marine casualty, they serve as a reminder to the potentially dangerous results that may occur when an alarm system is deliberately ignored. A false sense of operational safety develops when crew members continually silence what they consider to be a “nuisance alarm,” enabling a false perception of normalcy to develop. Inspectors observed on two vessels that repetitive alarms occurred every time crew members performed steering tests that attempted to move the rudder through its range of motion. The alarms indicated that “hydraulic lock” events had occurred. Each time, the alarm was simply acknowledged by the crew and the steering gear adequately moved the rudder. However, no further investigation was conducted to identify the cause of the alarm. 

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I am teaching another 1-Day Course for ASSE

Intro to Process Safety Management

February 13, 2017

The Rio, Las Vegas, NV



My Friend Jonathan Zimmerman and I are presenting at ASSE's Safety 2017

Topic:  Safe Work Permit Management System

Day and Time to be posted later. 

I am also working on details to do a

POST conference PSM course in CO as well.

Details to be posted later.


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