Archive for the ‘Regulations’ Category

Regulating Reactive Chemicals

Friday, October 2nd, 2009

Recently, members of  Congress sent a letter to OSHA chief, Jordan Barab, to expand PSM standard to address reactive chemicals. Reactive chemicals have gained increasing attention since the Chemical Safety Board (CSB) released its report on reactive chemicals in 2002. Now I have been working in the area of reactive chemicals ...

CSB: To Investigate Or Not To Investigate

Wednesday, September 16th, 2009

Last year, the Government Accountability Office (GAO) reported that the Chemical Safety Board (CSB) is not meeting its statutory mandate by investigating major chemical accidents. CSB’s Statutory Mandate The Clean Air Amendment Act (CAAA) of 1990 directs CSB to (1) investigate and report on the cause or probable cause of any accidental chemical ...

OSHA Chemical NEP

Monday, September 14th, 2009

On July 27, 2009 OSHA launched its National Emphasis Program (NEP) targeted at chemical facilities. The NEP will operate as a one-year pilot program during which OSHA will conduct planned inspections of chemical facilities. Which Chemical Facilities Will Be Reviewed? The Chemical NEP will focus on facilities in the following regions: Regions ...

Have You Considered Inherently Safer Alternatives?

Wednesday, September 2nd, 2009

Inherently safer philosophy represents a slightly different approach to risk mitigation. Instead of focusing on mitigating risks, an inherently safer alternative focuses on eliminating the hazards.Let us look at couple of inherently safer examples. HF Alkylation There are four alternatives available to perform alkylation: Pure HF: Potential high ...

RAGAGEP

Monday, August 10th, 2009

RAGAGEP stands for Recognized And Generally Accepted Good Engineering Practices. Specifically, OSHA 29 CFR 1910.119 (D)(3)(ii) states:The employer shall document that equipment complies with recognized and generally accepted good engineering practices. EPA RMP also refers to RAGAGEP in 40 CFR 68.73:Inspection and testing procedures shall follow recognized and generally accepted good engineering ...

Primer on Pipeline Integrity Management

Monday, July 20th, 2009

A few weeks ago I met with Cesar de Leon who is a pipeline safety expert (http://www.pipelinesafetyconsultant.com) - he worked at the DOT Office of Pipeline Safety for over 23 years and currently resides in Boerne, Texas. Cesar was telling me about legal and technical issues arising in the ...

Overview of Chemical Plant Security

Tuesday, July 7th, 2009

Chemical Facility Anti Terrorism Standard (CFATS) came into force on Nov. 20, 2007 as a Federal Regulation under 6 CFR 27. This set into motion the process of assessing threats to chemical plants and refineries in the U.S. Photo Courtesy: http://www.flickr.com/photos/8177037@N06/ / CC BY-NC 2.0 ; Step 1: Is Your Facility ...

GAO: CSB Not Meeting Its Statutory Mandates

Monday, June 22nd, 2009

According to a recent report (Aug. 2008) from the Government Accountability Office (GAO), the Chemical Safety Board (CSB) is not in compliance with its statutory mandates.  The CSB is an independent federal agency charged with investigating industrial chemical accidents and has been in operation since 1998. GAO report states that ...

OSHA Working on Dust Explosion Regulation

Sunday, May 17th, 2009

OSHA is currently working on regulation for preventing dust explosions. The first reported dust explosion was in 1890 in a sugar mill in Chicago. According to the CSB investigation, dust explosion has resulted in 130 deaths and 780 injuries since 1980. According to Combustible Dust Institute research of news reports, there ...

OSHA NEP to Focus on the Chemical Industry in 2009

Sunday, April 19th, 2009

In 2007, after investigating the explosion and fire at BP's Texas City facility, the US Chemical Safety and Hazard Investigation Board (CSB) recommended OSHA to launch a PSM National Emphasis Program (NEP). The objective of the NEP was to reduce the hazards associated with petroleum refineries. As a part of ...