Process safety and risk management professionals are well aware that the laws of Process Safety Management (29CFR1910.119) and the Risk Management Program (40CFR68) have been a driving force of safety advancement in the industrial chemical sector. Within the last decade the inspections of these laws have opened the eyes of many within Industrial Ammonia Refrigeration industry and developed a new respect to what we call PSM/RMP. From early 1990 to late 2017, these two laws had much similarities in regards to the 14 elements of process safety.
What most implementer of these laws don’t know is the politics from the powers to be at Washington DC. Below is the madness of new law writing process that stemmed from the Obama administration (executive order 13650).
So what does this all mean… As of December 19, 2019 we are closer to where we where before all this madness began. EPA’s newest law was rescinded and replaced. Will the new law stay? Who knows! What we do know is the original EPA law stood for about 25 years. That law was recognized and established and almost all requirements of it moved into the new law and therefore make sure your programs meet all those requirements. In your next PSM meeting discuss all the new requirements and there effective dates. If you missed the post of what was rescinded of the EPA’s recent new law visit this link. If you would like to see what is filed currently in the federal register please visit this link.
“The only way to avoid breaking the law is to have no law to break” – Book of Romans
If you need any help or guidance with this give us a call or shoot us an email. Many blessing to you all in this new year of 2020!
