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When dealing with processes involving combustible dust, flammable liquids & gasses, and extremely toxic materials, understanding the hazards in the process is critical. This is true when designing a new process, as well as when a plant changes equipment, chemicals, and procedures. Many of the most severe industrial accidents have occurred because the facility failed to consider how changes would impact process safety. That is why a robust management of change (MOC) procedure that incorporates process hazard analysis (PHA) is so important. Continue reading “The Importance of Management of Change and Hazard Analysis”

For several years, NFPA has been working to develop NFPA 652, Fundamentals of Combustible Dust. According to Guy Colonna’s recent article in NFPA Journal, the standard is due out this summer(1). This standard will be an overarching standard that applies to all facilities where combustible dust or particulate solids are present. CTI will provide detailed information once the final standard is released. Brian Edwards, PE of CTI has attended the development meetings for that standard, and he is available to answer any questions you may have about the new standard, or the existing, industry-specific standards.

(1) Colonna, Guy. (2015). ‘Credible Risk’. NFPA Journal, March/April 2015, pgs. 60-65

As of January 1st, 2015, the updated standards for injury & illness reporting officially came into effect. There are some slight changes to the standard that affect a large number of employers.

Under the old rule, employers were required to notify OSHA only of workplace fatalities or if three or more employees had to go to the hospital due to workplace injury or illness. According to the updated standard, employers must notify OSHA of the following: Continue reading “OSHA’s New Incident Reporting Requirements”

As a new year is upon us, it is once again time for reflection, new goals, areas of improvement, and it is time to be introduced to OSHA’s plans and expectations for 2015.

Depending on whom you are talking to, OSHA’s plans for 2015 and beyond are either ambitious and will drastically enhance worker safety in all industries, or OSHA has a weak agenda that alienates employers and fails to address the safety and health of the American worker. Read the rest of this article and decide for yourself. Either way, 2015 will be an important year to keep up with OSHA. Continue reading “What to Expect From OSHA in 2015”

The purpose of this article is to walk you through the Boiler MACT applicability, compliance dates and what regulations are applicable to your facility’s boiler and/or process heater. The full names of Boiler MACT and GACT as published in the Federal Register 40 CFR Part 63, is as follows: Boiler GACT (Generally Achievable Control Technologies), in short refers to the USEPA’s National Emission Standards for Hazardous Air Pollutants (NESHAP) for Area Source: Industrial, Commercial and Institutional Boilers. Boiler MACT (Maximum Achievable Control Technology) refers to the USEPA’s NESHAP for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters.

The Four Rules

To figure what rule applies to your facility, you first need to understand the Boiler MACT basic 4 rules. Boiler MACT is used in a generalized form to include the following specific rules: Continue reading “Meeting Compliance Schedule and Requirements of Boiler MACT”

Storm Water Violations Associated with Vehicle Washing

A common source of storm water pollution at industrial facilities is vehicle wash water. Any vehicle wash water that discharges from the facility to the outside would be in violation under the Storm Water Permit.  In fact, Georgia Environmental Protection Division (EPD) has specifically mentioned that they will evaluate vehicle washing activities while conducting site inspections.  Additionally, the U.S. EPA and the U.S. Justice Department have issued citations to several ready-mix concrete plants for failure to maintain best management practices associated with vehicle washing activities.  Monetary penalties for these vehicle washing citations totaled $360,000. Continue reading “HANDLING OF VEHICLE WASH WATER”

Those familiar with the Process Safety Management (PSM) of Highly Hazardous  Chemicals standard understand the importance of compliance audits of the program as well as the large scope of work the PSM program requires. The PSM standard is now over 20 years old. A proper PSM program will address the following areas: Continue reading “AUDITING OF THE PROCESS SAFETY MANAGEMENT (PSM) OF HIGHLY HAZARDOUS CHEMICALS PROGRAM”