Chemical Engineering November 2012 - 5

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REBEKKAH J. MARSHALL
Editor in Chief
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DOROTHY LOZOWSKI
Managing Editor
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GERALD ONDREY (Frankfurt)
Senior Editor
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SCOTT JENKINS
Associate Editor
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CHARLES BUTCHER (U.K.)
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Are you ready for inspection?
L
eading up to this month's 2012 U.S. Presidential election, the legislative
landscape has been relatively uneventful. On top of their preoccupation
with the election campaigns, lawmakers on both sides of the political
spectrum have been reluctant to pin their agendas to any bill that might
significantly alienate large groups of voters. Nevertheless, two relatively
significant changes are coming down the pike for hazardous-chemical manufacturers
in the U.S. Both of them are coming from a group that does not
observe an immediate impact from the election cycle - the U.S. Occupational
Safety & Health Admin. (OSHA; Washington, D.C.; www.osha.gov) -
and both are being addressed in the ChemInnovations conference program
later this month (New Orleans, La.; November 14-15; www.cpievent.com).
Chemical Facilities National Emphasis Program (NEP). The first
change is OSHA's Chemical Facilities NEP, which outlines a new approach
for conducting site inspections for the agency's Process Safety Management
(PSM) of Highly Hazardous Chemicals (29 CFR 1910.119). Part of the new
approach is to focus on whether a company's written PSM program is actually
being implemented. The program is an expansion of a 2009 pilot program
that covered a limited number of chemical facilities and is similar to OSHA's
NEP for petroleum refineries. Announced last November, the Chemical NEP
applies to over 6,000 facilities that manufacture highly hazardous chemicals.
Since there is no deadline or formal inspection schedule, however, the
majority of the anxiety at each facility is centered around the simple questions
of " if " and " when " an inspection might arise. " It could be next week
or next year. No one really knows, " says David Whitaker, a partner at
Kean Miller LLP (New Orleans, La.; www.keanmiller.com) and speaker at
ChemInnovations. For that reason, the most important thing you can do
is be prepared, he says. At ChemInnovations, Whitaker will help attendees
understand what the Chemical NEP means for them and how to be
prepared for an inspection if it happens. Meanwhile, his colleague Steven
Pereira, principal at Professional Safety Associates LLC (Denham Springs,
La.; www.professionalsafety.com), will present his experience with over 50
PSM audits in the petrochemical and petroleum-refining industries and
highlight typical " red flags " that get OSHA's attention.
Hazard Communication Standard (HCS). The second change is a revision
to OSHA's HCS, which for the first time includes combustible dust in the
definition of hazardous chemicals, and now requires training to specifically
include combustible dust hazards. Employers will be required to train their
employees by December 2013, with full implementation of the rule in 2015.
In his presentation, Impending Changes to OSHA's Hazard Communication
Standard, Steven Luzik, senior process safety specialist for Chilworth
Technology, Inc. (Princeton, N.J.; www.chilworth.com) will provide specific
details regarding the revised standard, including the following three major
changes to the previous version: (1) Hazard classification: The revised standard
specifies criteria for classification of health and physical hazards, as well
as classification of mixtures; (2) Labels: Chemical manufacturers and importers
will now be required to provide a label that includes a
harmonized signal word, pictogram and hazard statement
for each hazard class and category. Precautionary statements
must also be provided. Chemical manufacturers
and importers will be required to evaluate the hazards of
the chemicals they produce or import, and prepare labels
and safety data sheets to convey the hazard information
to their downstream customers; (3) Safety Data Sheets
(SDSs): MSDSs will now be referred to as SDSs. They will
now have a specified 16-section format.
■
Rebekkah Marshall
CHEMICAL ENGINEERING WWW.CHE.COM NOVEMBER 2012 5
http://www.osha.gov http://www.cpievent.com http://www.keanmiller.com http://www.professionalsafety.com http://www.chilworth.com http://www.accessintel.com http://WWW.CHE.COM
Chemical Engineering November 2012

Table of Contents for the Digital Edition of Chemical Engineering November 2012
