Recent Blog Posts

OSHA’s Clarification on RAGAGEP

September 15th, 2015

In an industry laden with acronyms, RAGAGEP is probably the most important to understand when implementing a process safety management program. Simply put, RAGAGEP is “recognized and generally accepted good engineering practice”. The PSM regulation, 29 CFR §1910.119 and Title 8 CCR §5189, directly references or implies the use of RAGAGEP in three provisions: Process Safety Information – (d)(3)(ii): Employers […]

Exit Sign Requirements

August 19th, 2015

I was recently asked about the requirements for Exit Signs within a facility. I learned that Fed/OSHA, Cal/OSHA, and the Building Code each require the installation of Exit Signs. Cal/OSHA Title 8 §3216(b) requires Exit Signs (or directional signs) to be installed “at every exit door, at the intersection of corridors, at exit stairways or ramps and at such […]

ASME Pressure Vessel Modification

July 22nd, 2015

A client recently modified an ASME ammonia pressure vessel that provided me the opportunity to dive into the requirements that must be adhered when performing such activities. Here is a summary of what I learned: 1. IIAR Standards IIAR doesn’t speak directly to the issue of pressure vessel modification, however,  ANSI/IIAR 2-2008 Addendum B §9.2 Procedures/Testing does […]

1982 Uniform Mechanical Code and “Adjoining Ground Level”

July 7th, 2015

Anyone who operates an “older” ammonia refrigeration system in California should be familiar with the requirements of the 1982 Uniform Mechanical Code. Cal/OSHA regulation Title 8 CCR §3248(a) requires the following: “Mechanical refrigeration systems placed in service before March 13, 1999, shall be designed, installed, tested, and maintained in accordance with Chapters 4, 15, and 16 […]

Propane and PSM

June 9th, 2015

Question: I am considering installing a propane tank at my facility, will it be subject to the requirements of RMP and PSM? Answer: Assuming that the propane tank will be used for forklift fuel, you are not required to comply with the requirements of RMP, PSM, or CalARP because of the following exemptions/exclusions: Title 40 CFR §68.126 A […]