SUBJECT: O.S.H.A. 1910 REGULATION
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 library.
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 purpose.
- 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 training.
- 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 alternative.
- A sensible evacuation system is the third line of defense.
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 training program.