Hazardous Materials Storage
nstructions
- Some of the hazardous materials of concern utilized at MPPs facility are as shown below.
- Key facility PSM inspection observations were as shown below.
- The frequency of the inspection and testing of process equipment was not performed in accordance with the manufacturers recommendations, good engineering practices, or prior operating experience.
- Process equipment records for 65 of 422 records reviewed were missing either the name of the person who performed the inspection, the date of the inspection, or the serial number of the equipment.
- The process hazard analysis performed by MPP did not address all of the process hazards.
- MPP did not review or evaluate their contractors safety performance and safety programs during the contractor selection process.
- No written plan of action for the implementation of employee participation in PSM/safety activities was available for review.
- An incident investigation of a potentially catastrophic release of chlorine dioxide was not initiated as required by PSM within 48 hours following the incident.
- MPPs Emergency Action Plan does not include procedures for handling small releases of hazardous materials.
- Discuss the purpose of OSHAs PSM standard, including why it was initially implemented and its scope. Explain why MPPs pulp mill manufacturing process is considered a covered facility under OSHAs PSM standard. Identify which hazardous material(s) used at the pulp mill facility exceed the threshold quantities (TQ) shown in 29 C.F.R. 1910.119 Appendix A.
- Describe an oxidizer. Identify at least three oxidizers used at this MPP facility, and discuss their potential hazards to human health and the environment. Based on the OSHA 8-hour permissible exposure limit (PEL)/time-weighted average (TWA) for your three identified oxidizers, which one would pose the greatest threat to human health? Explain why, and elaborate on how you should respond if this oxidizer is accidentally released.
- Review the OSHA inspectors preliminary observations, and provide recommendations regarding how MPP can improve their compliance with at least three elements of OSHAs PSM standard. Each recommendation you provide must discuss the noncompliance issue(s) observed, the specific PSM standard requirement, and what program changes need to be implemented to improve your companys PSM compliance.
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