CLIENT ALERT: Environmental Justice and Regulatory Impacts

On January 27, 2021, the Biden Administration put forth Executive Order 14008, creating the White House Environmental Justice Interagency Council. Environmental Justice (EJ), as defined by the EPA, is “the fair treatment and meaningful involvement of all people regardless of race, color, national origin, or income with respect to the development, implementation and enforcement of

A Holistic Approach to Process Safety Management

The Code of Federal Regulations (CFR) 1910.119 lists 14 program safety elements required by the Occupational Safety and Health Administration (OSHA) for processes involving highly hazardous chemicals that are used or stored in a location in certain quantities. Each of these 14 elements contain additional components required for the programs, and some of the elements

CLIENT ALERT: Process Hazard Analysis (PHA) Revalidation

On February 24, 1992, OSHA implemented the Final Rule for Process Safety Management of Highly Hazardous Chemicals. Officially adopted in 1996, OSHA Standard 29 CFR 1910.119 established uniform policies, procedures, standard clarifications, and compliance guidance for enforcement of the standard for process safety management (PSM) of highly hazardous chemicals. OSHA required all PSM covered processes