One of the top questions I receive is asking about how NFPA 704 ratings play into the application to OSHA's Process Safety Management standard and EPA's Risk Management Plan rule.  I hope to clarify any confusion this NFPA 704 application may be causing, as YES - the NFPA 704 does have a role in determining if certain MIXTURES fall under the RMP rule.  However, this ONLY applies to certain FLAMMABLE MIXTURES and ONLY is used in EPA's RMP rule - NOT in OSHA's PSM application.  Let me explain ...

OSHA has started its Small Business Advocacy Review Panel in order to get feedback on several potential revisions to OSHA's Process Safety Management Program (PSM) standard.  The modernization topics OSHA is considering stem from industry best practices, inspection history, stakeholder comments received in response to OSHA's 2013 Request for Information and lessons learned from accidents involving highly hazardous chemicals.  Topics to be considered by the Small Business Panel include:

The Committee recommends $552,787,000 for the Occupational Safety and Health Administration [OSHA], which is responsible for enforcing the Occupational Safety and Health Act of 1970 in the Nation’s workplaces. The Committee continues bill language to allow OSHA to retain course tuition and fees for training institute courses used for occupational safety and health training and education activities in the private sector. The cap established by the bill is $499,000, the same as current law.  The bill retains language that continues to exempt farms employing 10 or fewer people from the provisions of the act with the exception of those farms having a temporary labor camp. The bill also retains language exempting small firms in industry classifications having a lost workday injury rate less than the national average from generally scheduled safety inspections.  The exemption of small farming operations from OSHA regulation has been in place since 1976. OSHA clarified the limits of its authority to conduct enforcement on small farms in July 2014, particularly regarding post-harvest activities of a farming operation. The continued exemption for small farms and recognition of limits of the OSHA regulatory authority are critical for family farms. It is also important the Department of Agriculture is consulted in any future attempts by OSHA to redefine or modify any aspect of the small farm exemption.

Screen Shot 2016 06 01 at 9.47.35 PMReaders of my Incident Alerts may remember this NH3 fatality from September 2012...

AMMONIA FATALITY Winery worker dies after ammonia exposure (a worker at a winery has died after being exposed to ammonia - one of the workers accidentally opened a wrong valve and released ammonia into a confined area - the man was one of six workers exposed - the other workers tried to rescue the man but were unable to get to him because of the fumes - he died at the scene - the other employees were treated and released)

Now CAL-OSHA has shared some details not previously released...

Many working professionals may not be aware that some states and territories have their own OSHA and others are covered by Federal OSHA.  In fact, twenty-six states, Puerto Rico, and the Virgin Islands have OSHA-approved State Plans. Twenty-two State Plans (21 states and one U.S. territory) cover both private and state and local government workplaces. The remaining six State Plans (five states and one U.S. territory) cover state and local government workers only.  But recently, OSHA came to an agreement with the state of Hawaii that was interesting...

For those living the dream of being a process safety professional know that one of the fundamental decisions we eventually have to make is how will we "class" our PSM/RMP covered process piping.  For almost all of us, the best Piping Inspection RAGAGEP will be API 570, Piping Inspection Code and this RAGAGEP has a very ingenious way of "classifying" process piping based on its content and a degree of hazard.  But like many RAGAGEPs, it provides us "guidance" and this opens the door to questions and incorrect decisions.  In this article, I hope to convince you that our PSM/RMP covered process piping should land in Class 1.

 
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