Yes. When OSHA enacted the PSM requirement, it did so in an effort to eliminate or minimize catastrophic incidents involving highly hazardous chemicals. PSM programs are risk reduction strategies. When implemented correctly, reducing storage inventories of highly hazardous chemicals and isolating stored quantities in distinct facility areas are acceptable risk reduction strategies. Employers at storage facilities may therefore choose to safely alter their storage practices to reduce chemical risks—and fall below PSM applicability criteria—instead of complying with PSM. However, such facilities must still comply with other applicable OSHA standards and section (5)(a)(1) of the OSH Act, the “General Duty Clause” (which requires that employers provide workplaces free from recognized hazards that are likely to cause death or serious physical harm).
OSHA has published a DRAFT revision of their OSHA 3132, Process Safety Management. This new version is NOT meant to be a replacement for OSHA 3132, but instead meant to be a companion to the original OSHA 3132 specifically for small businesses that may be impacted by the PSM standard. The booklet calls attention to five (5) of the fourteen PSM elements that may have the most impact on small businesses and their process risks...
The diffuser tank discussion continues and Peter Thomas, P.E. from Resource Compliance, Inc. was kind enough to offer us the following insight as to when a diffuser tank would be required. In most of my postings, I reference the International Fire Code (IFC) and International Mechanical Coden(IMC) quite often, but the Uniform Mechanical Code (UMC) is a code that I have very little experience with and as Peter points out, it is alive and well on the west coast. So it is worth noting that the Uniform Mechanical Code required Diffusion Tanks from 1994-2014 (the requirement removed in 2015 UMC)AND the UMC also required diffuser tanks be of steel construction. Most states utilize the International Mechanical Code, but select western states still use the UMC, or in the case of California the California Mechanical Code which is a derivative of the UMC. Here are some parts of the UMC that Peter provided:
This past week I was having a conversation with my friend and fine PSM professional Brian Chapin @ RCE and our discussion turned to diffuser tanks. Having been involved in several design and install projects over the past several years, getting to know a little something about diffuser tanks comes with the territory. But one of my biggest battles has been the use of "farm tanks" (i.e. plastic tanks) as diffuser tanks. We laughed for a moment and Brian in his usual fashion brought it all home with the question... what RAGAGEP are you using for your diffuser tank(s)?
This incident shows us that just because a pipe contains a chemical that may not be included in a PSM/RMP program, it does not mean the level of risk is any less. This explosion was caused by construction workers using a cutting torch to remove old piping from a boiler room and cut into a pocket of residual propane. The workers were removing discontinued piping that was used for fueling the boiler. One of the pipes had residual propane still inside it and when workers began to cut the pipe with a cutting torch, the propane flashed inside the boiler room.
2016 will go down as the year OSHA and EPA tried to revamp their PSM and RMP rules for handling Highly Hazardous Chemicals (HHC) and Extremely Hazardous Substances (EHS). We have even seen Congress get into the act of blocking OSHA from enforcing PSM on fertilizer distributors. All the while, our friends to the north have been busy implementing their "Fertilizer Canada Anhydrous Ammonia Code of Practice" which go into effect January 2017. Fertilizer Canada is an industry association representing Canadian manufacturers, wholesalers and retail distributors of nitrogen, phosphate and potash fertilizer used in the production of agricultural crops. And this group of companies has developed a "certification" in which ONLY facilities certified as compliant with Fertilizer Canada’s Ammonia Code of Practice (Code) are eligible to receive shipments of anhydrous ammonia. If situations exist where "uncertified facilities" are receiving product or facilities are not in compliance with the Code, a third party complaint process exists to report, investigate and take remedial action. Compliance with the Code may also be randomly verified by Fertilizer Canada through the Quality Assurance/Quality Control program where an auditor may be sent to a certified site to verify compliance at any point during the certification period. The frequency for auditing is every two years (730 days). But it is some of the "facility siting" elements that caught my eye during a visit...