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ISSUE 19 -  2014

This issue:

PSM for

Ammonia Industry

     
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OSHA's PSM Standard

What does the code say?

What does it really mean? 

Click below to find out 

 

Employee Participation
MOC
Incident Investigation
Emergency Planning and Response
Operating Procedures
Compliance Audit
Trade Secrets

 

 

Process Safety Information
PHA
Training
Contractors
Pre-Startup Review
Mechanical Integrity
Hot Work Permit

PSMCI Services

PSM GAP Analysis

Find out for sure

if your ready for OSHA

 Contact PSMCI today for a quote

At PSMCI we a offer a vast range of client service programs exclusively for the ammonia industry. Our goal is to assure that you achieve and maintain regulatory compliance under OSHA 29 CFR 1910.119 and the EPA’s 40 CFR Part 68.

The PSM GAP Analysis developed by PSM Compliance, Inc. is a comprehensive and detailed inspection and review process of your entire PSM program. All fourteen elements of PSM as developed and implemented at your facility are scrutinized to assure compliance issues have been addressed, documented, and meet regulatory compliance. The scope of the aanalysis will include: 

1)     A comprehensive review of your existing PSM Program to assure your written plan for achieving regulatory compliance meets both OSHA and EPA regulatory guidelines.

2)     A thorough examination of all support documentation developed and implemented by your facility to ensure ongoing compliance objectives are being maintained. Review includes:

a)    Employee Participation. How much do they know, how much are they involved?

b)    Employee and Contractor Training programs (is level of training equal to level of responsibility?).

c)    Operating Procedures (structure, content, and implementation).

d)    Management Of Change (structure, follow-through, Pre-Startup Review).

e)    Incident Investigations (do they include near-misses and root cause?).

f)     Process Hazard Analysis (quality and comprehensiveness of the study).

g)    Audits (thoroughness and follow-up of recommendations) .

h)    Mechanical Integrity (are you following “generally accepted good engineering practices” as mandated by the regulation?).

i)      Emergency Planning and Response (evacuations, alarm systems, first responders).

3)    Interviews with a representative sampling of employees and key operations personnel.

4)    Upon completion, a detailed summary report is generated which will detail non-compliance issues along with proposed recommendations for meeting regulatory compliance.

 The PSM GAP Analysis is a tool to help you recognize and correct regulatory issues that may exist at your facility. Unlike a formal PSM Audit, which requires a record retention of six years and must be made available to OSHA inspectors, the PSM GAP Analysis is non-regulatory and any non-compliance issues identified or recommendations generated as a result of the analysis are not required to meet any federal record retention schedules and, unless volunteered, would not be subject to the normal OSHA inspection process.  

Call us at (281) 685-8348 or email us HERE for more information

 

           

RMP

 the Environmental Protection Agencies (EPA) Risk Management Plan (RMP) should be reviewed annually to assure information is accurate and up-to-date. A viable and functioning PSM program is a big part of that plan.

Email us today for more information or call us at 281-685-8348 

RMP GUIDANCE FOR AMMONIA REFRIGERATION (40 CFR PART 68)

United States Environmental Protection Agency Office of Solid Waste and Emergency Response

(5104) EPA 550-B-00-006 May 2000 www.epa.gov/ceppo/ 

8.3 RESUBMISSION AND UPDATES (§ 68.190) 

WHEN DOES THE OFFSITE CONSEQUENCE ANALYSIS (OCA) NEED TO BE REVISED?

You’ll need to revise your OCA when a change at your facility results in the distance to an endpoint from a worst-case release rising or falling by at least a factor of two. For example, if you increase your inventory substantially or install passive mitigation to limit the potential release rate, you should re-estimate the distance at an endpoint. If the distance is at least doubled or halved, you must revise the RMP. For most substances, the quantity that would be released would have to increase by more than a factor of five to double the distance to an endpoint.

What is the first thing OSHA will ask to see when they pop in for a PSM inspection?

Find out HERE!

 

Machine room requirements under (ASHRAE 15)

ASHRAE has approved and published an Addendum to the ASHRAE 15 safety standard.

The Addendum defines requirements for refrigeration machinery rooms:

 

1. Self-contained breathing apparatus (SCBA) is no longer required outside the machine room. This requirement was removed due to the danger of untrained personnel using the SCBA.

 

2. Machinery room detector and alarm requirements have been significantly strengthened, including visible and audible alarms outside each machinery room entrance.

 

3. Signage is required to prohibit entrance while the alarm sounds. The facility emergency procedures (already required by ASHRAE (15)) must deny entry to untrained/unequipped personnel. The minimum requirements in the new addendum forbid entering

after an alarm, virtually guaranteeing a HAZMAT call and an expensive plant shutdown. An informative appendix helps plan for emergencies and avoid this. This is a good time to evaluate the condition of your facility’s refrigerant detector system, along with the alarms, ventilation, and shutdowns to which it is connected.

A full copy of the Addendum is available on the ASHRAE website.

 

2007 PSM Compliance Inc. - OSHA Compliance for the Ammonia Industry




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