General Duty Clause Requirements: Identifying Hazards Using Appropriate Hazard Assessment Techniques

May 17, 2023
11:00 am - 12:00 pm Eastern (U.S.) Time

IIAR Members: FREE
Non-members: $50

DESCRIPTION

ENFORCEMENT AWARENESS!

The U.S. Environmental Protection Agency’s (EPA) National Enforcement and Compliance Assurance Program implemented several national compliance initiatives (NCIs) effective for FY2020-2023. One of these NCIs is titled “Reducing Risks of Accidental Releases at Industrial and Chemical Facilities.”

IIAR has received notice from the EPA (confirmed by multiple end-users) that one area of the agency’s focus is to determine whether facilities using hazardous chemicals have conducted a hazard analysis. EPA is citing the Clean Air Act Section 112(r), which establishes the regulations of the Risk Management Program for facilities using large quantities of a hazardous substance. EPA is also citing the General Duty Clause, which is also a part of CAA 112(r) and applies to facilities using any quantity of hazardous substances. In addition to its process safety management (PSM) regulations, the U.S. Occupational Safety and Health Administration (OSHA) also enforces a general duty clause that requires a hazard analysis.

We will also examine the various methodologies that can be used to determine and evaluate the hazards for processes of any size, as well as explain how systems of different sizes can be tailored to comply with the General Duty clauses.

Join IIAR for an informative webinar that will examine the General Duty Clause requirements and the implications of those regulations for industrial refrigeration facilities.

LEARNING OBJECTIVES

After participating in this activity, participants will be able to…

• Discuss the importance of a hazard analysis for operation of an ammonia-based refrigeration system and why EPA is focusing on this requirement of the Clean Air Act.
• Understand that the General Duty Clauses require a process owner to identify hazards using an appropriate hazard assessment technique, no matter the size of the system.
• List the methodologies that can be used to determine and evaluate the hazards of the process being analyzed.

SPEAKERS

Tony Lundell, CIRO, PMP
Senior Director of Standards and Safety
International Institute for Ammonia Refrigeration (IIAR)
Alexandria, VA