The 88th Michigan Safety Conference will be coming to the Lansing Center on April 17-18, 2018. Mark your calendar for this premier event.
And, come visit with our SRM professionals at Booth 913.
Please join us on April 21, 2018 at Lake Harbor Park in Norton Shores to beautify our park and lakeshore and enjoy some time outside.
This is Earth Day weekend and what better way to show your love for mother earth and your community. We’ll start at 10 am and be finished by 11:30 am.
We hope you can join us! Click here to Sign Up
The OSHA PSM Standard (29 CFR 1910.119) is a “performance” standard rather than a “prescriptive” standard. In other words, the standard doesn’t tell you exactly what to do, such as when to collect a sample or log temperature. Rather, the PSM Standard requires you to achieve a certain level of performance. Then it is up to you to figure out how to maintain performance at that level. MIOSHA has adopted these regulations in GI Part 91 and OH Part 591.
The PSM Standards consist of 14 “Elements.” These “elements” are broad categories of compliance, like “Training” and “Employee Participation", each having its own set of requirements and goals that you set and then meet.
“14 elements!,” you sigh and think, “how am I going to get all of this work done when there is only one of me!” Let’s begin to answer with this – start with OSHA’s guide for small businesses entitled, Process Safety Management for Small Businesses. A copy can be found here.
In this guide OSHA identifies Process Safety Information (PSI), Process Hazards Analysis (PHA), Training, Mechanical Integrity (MI), and Compliance Audits as the elements most relevant to hazards associated with small businesses. Although all 14 elements will eventually need to be completed, this is a good place to start your PSM Program development. Why do you think OSHA started with these elements? Well, because by doing them you will be successful at making a good product and preventing your employees and neighbors from exposure to a highly hazardous chemical.
Process Safety Information (PSI)
PSI includes a variety of information about your system, such as design and operating specifications for piping, vessels, valves and gauges. It includes drawings (P&IDs) showing the system layout, process flow and safety systems. This information will help your operators know when the system is operating in the sweet spot and when something is going wrong? The P&IDs will enable you to look up information about your system and see how its pieces and parts fit together and flow. Your maintenance team will be able to order and install the right equipment because they will know what design specifications they need for replacement parts. It is fairly straightforward. Your PSI and all the information about your system needs to be accurate and kept up to date because the rest of your PSM program is built around the PSI information.
Process Hazard Analysis
Why do you need a PHA? Why can’t I just copy the PHA from the plant down the road that is really similar to mine? Because one size does not fit all. Even though some systems are considered “Off-the-shelf,” your equipment numbering system will likely be different and your system probably won’t have exactly the same configuration for piping, valves and safety equipment. Each system is different, so you cannot just copy another PHA and call it your own. Besides, your team has to go through the exercise. The PHA is a great learning and exploratory opportunity and a great tool for identifying weaknesses, even in the best systems. And, believe me, by the end of the PHA your team will discover weaknesses and things they didn’t know about before the exercise started.
Effective preventative maintenance is one of the best ways to keep the highly hazard substance in your PSM regulated system and avoid deadly and costly accidents associated with worn valves, piping and gauges. This includes inspections of system components, exercising valves, ensuring gauges are working correctly and timely replacement of worn components. Training of the maintenance technicians keeps them safe and ensures replacements and repairs are done according to established codes and specifications.
Training is obvious, I think. Does a front desk receptionist need the same training as a maintenance technician? No. Staff and operations personnel need to be trained to the level of their involvement with the system. Everyone, at a minimum, needs to understand what their responsibilities are and what to do during normal operations and during emergencies. Office personnel need to know the dangers of the chemicals they are working near and what to do during an emergency.
If the suggested elements in the small business guidance document supposedly have something to do with the information about the system, why are compliance audits included in this list? Probably because an audit is a good place to figure out where you are in the whole process of developing a PSM Program. Or if you happen to have a mature program, an audit is a good way to have a fresh set of eyes review the program to identify opportunities for improvement or to check if the documents describe the activities actually implemented at your facility. Remember the old industry adage, Plan Do Check? This is the check part.
Another element I feel is important, but, is not in the OSHA guide as one of the five important elements mentioned earlier, is standard operating procedures (SOPs). This element, when done correctly, helps you make good product or refrigerate efficiently. If your procedures are wrong or ignored, it can result in employee injuries, equipment damage, raw material wastes and allot of wasted process time and money. On top of that, training of operators is critical, so they know how to keep the system in the sweet spot, how to recognize out-of-control conditions and then how to respond in a way that shuts the system down safely or brings it back under control. Oh, and they are a great training tool, too. So, you tell me if operating procedures are important or not.
It is a big job, but it doesn’t have to be overwhelming. By now you realize you alone cannot develop and implement a PSM program. It takes a team of operators, mechanics, engineers, their managers and of course, you, the compliance professional to get it all done.
SRM’s PSM professionals have been helping clients with their PSM programs for 20 years. We can evaluate your program, prioritize your opportunities for improvement and help you ensure your PSM program is effective and compliant. Just give us a call and we’ll show you how!
I had never seen the TV show This is Us before. I just happened to record it after the Super Bowl because I had heard it was good. Well, being a safety person I hit the jackpot. I don’t normally get choked up about TV characters, but this one hit close to home.
I was reminded of the fire escape plan I made with my kids years ago when they were young. I even remember sitting on the roof with my daughter outside her second-story bedroom window one evening so she would not be afraid of walking on the roof if she had to escape a fire. I remembered my insistence about changing the batteries in the smoke detectors, not just taking them out when they get low and start to chirp. Yes, I was a pain in the …. So, back to the show.
Both floors of the house are involved in what appeared to be a raging inferno. Then, Jack goes back into the house to retrieve the family dog. STOP!! OMG!! What were the writers thinking! When he came out the front door I cried “Foul!” to the writers and producers for allowing him to exit the house so unscathed, hardly even coughing. After all, the house was fully involved. If the smoke didn’t get him, the heat surely would have. Then, later it happened, Jack had cardiac arrest at the hospital.
At that point I felt somewhat gratified that the producers tried to make the show somewhat real, but in reality they should never have allowed Jack to exit the house except maybe as a smoldering heap. Because of the way it was done, it looked like it is possible to walk through a house fire like that and come out OK. For those of you that have been in a real fire, you understand the impact of the heat and smoke and how it burns the eyes and lungs and causes severe disorientation… Anyway, it is TV after all.
But you know what? I am actually grateful that the writers and producers killed off a main character because it started a conversation about smoke detectors and home fire safety. And, that made it all worth it! Rest in peace Jack. …. Oh, and don’t forget to change those smoke detector batteries!
There is a nice NFPA article on the This is Us TV show that can be found here.
A forklift operator was recently sentenced to 2 ½ years in prison for the forklift death of another contract worker at the Honda R&D Americas facility in Raymond, Ohio. The incident took place two years ago. When tragic incidents like this happen we need to ask what message should this verdict send to safety managers, supervisors and employers?
While we don’t have OSHA’s write-up, we can look at the facts as presented in the news story. The operator was known to drive through stop signs and drive forward when he had a load that blocked his view in front of the forklift. These two unsafe work practices are what lead to the accident. I would bet that everyone who has worked at a factory or warehouse for 2 years or more has seen this type of behavior at least once. And, that supervisors and managers know who the culprits are. The question is, what should companies do about this poor safety behavior? And, how long should the behavior be allowed to continue before effective intervention occurs?
Having been a safety manager, this story sent a chill up my spine. I hope it also sends a chill up the spine of every business owner, manager, supervisor and safety manager out there. Not because I enjoy seeing people sweat, but because too often I see companies on the surface claim “Safety First”, but behind the scenes they don’t always “walk the walk” by engaging their employees and contractors about safety and enforcing their own safe work practices.
Conversations about safety must occur regularly among hourly and management employees and contractors, training has to be up-to-date and relevant and safe work practices must be enforced consistently as part of every company’s culture. In this way, all employees are engaged in safety, and not just paying it lip service.
Research has shown us that employers who engage their employees and contractors about safety actually discourage poor behaviors and eliminate opportunities for preventable incidents like this one.
This is a chilling story and one that I hope never happens to any of our readers. But I also hope that it will serve as a reminder to everyone that if we as business managers let things go too far and don’t intervene, we can expect to see tragic incidents like this one happen again. I encourage everyone reading this article to download the news story and share it with supervisors and managers, and discuss the high personal loss for family and friends and the legal ramifications for individuals and the companies associated with the incident. And, ask the tough questions. How is our safety culture? Do we monitor effectively for unsafe work practices or unsafe conditions? How well do we interact with our contractors about safety? The local news story can be found here.
When it comes to industrial storm water management, historically we have always been concerned about preventing industrial materials from coming in contact with precipitation and draining into nearby storm drains, streams and lakes. We were able to accomplish this by not really knowing where all our drains went or how they were connected beneath our properties.
Now some may argue, “it just ain’t so! But, the fact is many companies out there don’t know or remember where all the underground drainage lines are, and they might not all be present on those old drawings. Were they moved? Were they abandoned or plugged? Sometimes our maintenance departments don’t have any definitive records about these underground structures.
This situation presents a real predicament with the addition of the new visual water sampling requirements in our general storm water permits. Not only do we need to collect and visually evaluate samples, we need to know where on the property the water came from for each of those samples. Basically, we need to divide our facility and property into drainage areas.
Each drainage area has a place where it discharges off-site into a storm drain, ditch, stream or lake. That discharge point becomes a sampling point. For some facilities it may be one sample location, but for others, it may be three or four sample locations.
For those of you with facilities in other Michigan Compliance Year river basins or other states, these requirements are likely familiar to you and you are already complying at those facilities. But for those for whom these requirements are new, it will take some level of effort to properly evaluate the drainage characteristics of your facility so you can feel comfortable with and can demonstrate to your local inspector that you know where the water is coming from and where it is going.
So, what do you do about it? A little detective work and taking a close look at your catch basins and culverts can help. Dust off those old drawings if you have them and consider calling Charlie the retiree who was your facility plumbing expert for 30 years. In some extreme cases, you may consider conducting a dye study.
Once you delineate your drainage areas and identify where the storm water is going, then you can select your sample locations. If your facility is relatively homogeneous with respect to industrial materials, parking lots and storage areas, you may be in luck. The permit allows you to alternate similar drainage areas for sampling. For example, if two of your drainage areas (Area A and Area B) both have the same operations, materials and vegetative characteristics, you sample from area A during one quarter and then from area B during the next quarter. To do this, drainage areas need to be very similar in their characteristics, so make sure you carefully document why they are similar in your Significant Material Inventory.
When finalizing your sampling locations, remember to include safety considerations so that the samples can be collected easily, safely and with little explanation to the person doing the sampling. Lowering someone down the side of an embankment using a rope is not a good way to collect storm water samples. Buy or fabricate sample devices that will make the sampling job easy and more importantly safe. For example, a pole with a sample jar clamp on the end will allow you to reach hard to get to places. You can also consider lowering a sample jar attached to the end of a rope into a manhole.
In some cases, you might consider installing a sample platform where a culvert discharges into a ditch or stream. And of course, traffic cones or barriers and high visibility equipment for sample locations near roads and driveways are also a must. Whatever you do, make sure you finish your hazard analysis and proof out your hazard mitigation techniques before the storm event arrives.
Need some help? Our Certified Storm Water Operator at SRM would be happy to answer your storm water questions. Give us a call!
Some economists say a little inflation is a good thing.
Well, when it comes to regulatory compliance, or in
this case non-compliance, it can be a bad thing.
In accordance with the Federal Civil Penalties Inflation Adjustment Improvements Act of 2015, the Department of Labor is required to adjust penalties for inflation each year. As a result, OSHA announced that the new penalty amounts, adjusted for inflation, as of Jan. 2, 2018.
New penalties for willful and repeat violations are $129,336 per violation. Serious, other-than-serious, and posting requirements are $12,934 per violation. Failure to correct violations are $12,934 for each day the conditions continue. These same penalties will be coming soon to a state program near you. More information can be found on the OSHA web page.
The next Hazardous Waste Biennial Report deadline is March 1, 2018 and covers activities during calendar year 2017. The Michigan DEQ will not be sending biennial packets to waste generators. Instead, Large Quantity Generators and TSDFs will be required to report using the federal forms and instructions.
While the MDEQ will accept paper copies, it is encouraging facilities to submit their Biennial Report data electronically through the Biennial Report component of the USEPA RCRAInfo Industry Application (RIA).
The RCRAInfo login page can be used to set up a RCRAInfo account and login. The web site provides guidance and information to be followed to prepare and submit the report. Additional information for submitting Biennial Reports to the MDEQ either electronically or on paper can be found at the MDEQ web site for Biennial Reporting.
If your facility uses or maintains a highly hazardous chemical in quantities above the threshold limit (often 10,000 pounds or more), then the Process Safety Management regulations apply to you.
Never heard of Process Safety Management? Process Safety Management, or PSM as the program is referred to, is an OSHA Performance Standard, which means that the regulations are not prescriptive. Instead, OSHA allows a facility to set up its program in a way that makes sense for the facility, as long as the program performs satisfactorily, the facility meets the regulatory requirements, and it keeps the highly hazardous materials within their containers.
The PSM regulations are outlined in 29 CFR 1910.119. MIOSHA has adopted these regulations in GI Part 91 and OH Part 591. We aren’t going to lie. There is a lot to digest and understand. But, OSHA provides a lot of useful information on its Process Safety Management webpage. It even published a Process Safety Management for Small Businesses brochure in 2017. You can find the brochure here.
PSM applies to toxic and flammable materials maintained in quantities above the thresholds listed in the standard. The OSHA list of highly hazardous chemicals can be found here. The MIOSHA list and regulations can be found here.
For companies with operations in Ohio, Ohio EPA adopted Ohio-specific universal waste rules allowing the following hazardous wastes to be classified and managed as universal waste in Ohio including:
These Ohio-specific hazardous wastes now can be regulated as universal wastes and join certain batteries, pesticides, mercury-containing equipment and lamps that are already part of the universal waste program in Ohio.
The rules became effective on December 21, 2017 and can be viewed on the Ohio EPA web site.
The designation of a hazardous waste as a universal waste streamlines the regulations that apply to the waste reducing the regulatory burden and costs, and promotes proper handling, recycling or disposal of the waste by generators.