The House Appropriations Committee has approved language blocking OSHA's efforts to cover Anhydrous Ammonia bulk processes located at "fertilizer businesses". The legislation now awaits consideration on the House floor. The bill prevents OSHA from revising a previous enforcement position relating to the "retail exemption" (1910.119(a)(2)(i) that would pull around 4,800 anhydrous ammonia fertilizer facilities into PSM.
CLICK HERE (pdf) to see the Letter sent to the committee by 41 Congressmen seeking to block OSHA. A couple of notes about this political wrangling:
Since our presentation at ASSE 2016 a couple of weeks ago I have been swamped with comments (all positive so THANK YOU) , questions and suggestions. One member thought the SAFTENG community could learn from one of the best chemical companies, Dow, on how they manage line break. We even had one attendee at ASSE 2016 mention some of Dow's practices related to Line Break/Equipment Opening. Here is a ppt Dow did recently for the World Chlorine Council.
This is a pdf file
The U.S. Chemical Safety Board (CSB) has formally announced that “Emergency Planning and Response” and “Preventive Maintenance” are the Board’s newest “Most Wanted Safety Improvements”. The CSB has concluded that inadequate or poor emergency planning or response is a recurring finding in the CSB’s investigations. And that inadequate mechanical integrity programs, delayed or deferred preventive maintenance, and the aging infrastructure of equipment at chemical facilities have been a recurring root cause of incidents investigated by the CSB.
For years now OSHA and EPA have taken similar approaches to how they view DOT containers (Tank Trucks and Railcars) when they are connected to a process. Both agencies have stated that as long as the motive power (e.g. tractor or locomotive) remains in place then the unloading falls under DOT and thus the content in the DOT container does NOT have to be counted towards our Threshold Determination. However, "drop the trailer/railcar" then we have to view the DOT container as a process vessel/storage vessel and consider its contents towards our Threshold Determination. Keep in mind that a single 55/90 Ton Railcar of Chlorine sitting on our property is in and of itself a "covered process" regardless of where it sits; however, co-locating it in near proximity may make the RCar part of the existing covered process. But recently some OSHA state plans have posed new views on this DOT application towards PSM/RMP...
The Department of Industrial Relations (DIR), the Governor’s Office of Emergency Services (Cal OES) and the California Environmental Protection Agency (CalEPA) today announced a landmark set of regulations to strengthen workplace and environmental safety at oil refineries across the state. The regulatory proposals are intended to make California refineries safer both for workers and surrounding communities. The two regulations implement key recommendations of the Governor’s Interagency Working Group on Refinery Safety, and are the result of a multi-year effort, including extensive consultation with workers, industry, NGOs, and communities, following a serious chemical release and fire at Chevron’s Richmond oil refinery in August 2012. The proposal includes two complementary regulations...