Archive for the ‘OSHA PSM’ Category

PSM 15th Element: Quality

Thursday, July 22nd, 2010

OSHA Process Safety Management (PSM) program is nearly two decades old and I believe that the 14 PSM elements provide a good basic framework for facilities to create a safety program. What OSHA PSM lacks is quality metric. Let me explain further. For example, one of the elements of the OSHA PSM is emergency planning. As a part of ...

Should the Cop Ticket Fred? Perils of Performance-Based Regulations

Wednesday, July 7th, 2010

When you are driving on a highway, usually there is a speed limit. If you exceed this limit, a cop can give you a ticket. In Houston, most highways have a speed limit of 65-70 miles per hour…although most drivers appear to assume it implies “90-mph is okay”. Let us say the ...

OSHA Combustible Dust Rulemaking

Thursday, January 28th, 2010

Stakeholder Comments on OSHA Combustible Rulemaking from John Astad's blog.

OSHA NEP Fines

Wednesday, October 14th, 2009

OSHA inspected 42 refineries between June 2007 - February 2009. Below is a summary of violations for 30 refineries. [Table=12] The average penalty for each violation is $ 5,650. The average penalty per refinery is $ 98,300.

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 ...

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 ...

Top Five Challenges for Process Safety

Monday, August 24th, 2009

Process Safety has evolved significantly since the introduction of PSM in 1992. Here are top five challenges facing the process safety community today. 1. Human Error One of the reasons “zero incident plants” is a myth is the potential for human error. We cannot take away human intervention and the possibility of ...

Is Your Emergency Response Plan Satisfactory?

Friday, August 21st, 2009

A chemical facility is mandated to have an emergency response plan by OSHA PSM and EPA RMP. An accident in the plant, a hurricane, and a potential terrorist attack are a few scenarios that mandate emergency response and planning. However, there is a vast difference between having an emergency plan ...

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 ...

Maintaining Process Safety During Tough Economy

Sunday, May 31st, 2009

We appear to be in a global recession – companies all over are struggling to deal with impact of economic slowdown. In an attempt to maintain profits, companies are drastically reducing their spending and also trimming down their workforce. It is anticipated that one-fourth of the employers in the US ...