SUBJECT: O.S.H.A. 1910
The regulation is predictably vague, and presently only applies to
pressure vessels, storage tanks, processing piping, relief and vent
systems, fire protection system components, emergency shut down
systems, alarms, interlocks and the part that is important to you,
pumps . For the first time Washington is telling the pump user that
he has to now document the training he provides to those people
(including contractors) that will be operating or repairing his
pumps. Be sure to pick up a copy of this regulation for your
Here are some of the ingredients you will find in the regulation
- The chemicals in the O.S.H.A. # 1910 specification are
different than those chemicals identified by the E.P.A. for
fugitive emission consideration. The O.S.H.A. list identifies
those chemicals that are considered "extremely hazardous"
chemicals. O.S.H.A. feels that the general industry standards are
not sufficient for these chemicals
- Your employer is going to have to create a Process Safety
Management audit team (PSM) that will audit company training
programs along with insuring that present and future engineering
practices conform to accepted standards and codes.
- The employer is going to have to identify the codes and
standards he relied upon to establish his engineering practices.
If he departs from these codes and standards, he must document
that the design and construction are suitable for the intended
- The written training programs must be reviewed for adequacy of
content, frequency of training, and the effectiveness of the
training in terms of goals and objectives. These training programs
must be revised if after the training the employee is not at the
level of skill or knowledge that was expected.
- Contract employees must also receive updated and current
- If an accident occurs, the plant is going to have to prove
that their training program was adequate.
- Any mechanical changes made by the maintenance department have
to be evaluated to determine whether operating procedures and
practices also need to be changed. The term "Change" includes all
modifications to equipment.
- For existing processes that have been shut down for turnaround
or modification, the employer must ensure that any changes other
than "replacement in kind" made to the process during shutdown go
through the management of change procedures.
- Equipment installation jobs need to be properly inspected in
the field for use of proper materials and procedures to insure
that qualified workers do the job.
- The employer must ensure that the contractor has the
appropriate job skills, knowledge, and certification.
- The regulations require detailed records of every action taken
in maintaining or rebuilding a pump. The employer must identify
which procedures were followed and why he elected to use those
procedures. He must also identify the training that maintenance
personnel had on repairing pumps in that service.
- Equipment used to process, store or handle hazardous chemicals
has to be designed, constructed, installed and maintained to
minimize the risk of release of such chemicals.
- The employer must prepare three lines of defense to prevent
hazardous chemical from injuring personnel:
- Contain the chemical in the equipment. The use of two
mechanical seals and a convection tank is a good example of
containing the chemical.
- Control the release of the chemicals through venting with a
seal quench and vent connection to a scrubber or flare, or to
surge or overflow tanks designed to receive such chemicals.
Dikes or designed drainage systems would be another
- A sensible evacuation system is the third line of
If an accident happens and any of the listed chemicals are
released to the environment, the employer is going to have to prove
he did every thing he could have to prevent the accident and contain
the spill. If O.S.H.A. does not agree with his assessment, the
employer is likely to suffer stiff penalties.
Since you have knowledge that 90% of mechanical seals are failing
prematurely (the carbon sacrificial face is not wearing out) I expect
this new regulation should encourage your employer to send more
people to seal and pump schools and enroll his engineering,
maintenance, and supervisory people in an appropriate certification
The Mc Nally Institute
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