The regulation is predictably vague, and presently only applies to pressure vessels, storage tanks, processing piping, relief and vent systems, fire protection system components, emergency shut down systems, alarms, interlocks and the part that is important to you, pumps . For the first time Washington is telling the pump user that he has to now document the training he provides to those people (including contractors) that will be operating or repairing his pumps. Be sure to pick up a copy of this regulation for your library.

Here are some of the ingredients you will find in the regulation :

If an accident happens and any of the listed chemicals are released to the environment, the employer is going to have to prove he did every thing he could have to prevent the accident and contain the spill. If O.S.H.A. does not agree with his assessment, the employer is likely to suffer stiff penalties.

Since you have knowledge that 90% of mechanical seals are failing prematurely (the carbon sacrificial face is not wearing out) I expect this new regulation should encourage your employer to send more people to seal and pump schools and enroll his engineering, maintenance, and supervisory people in an appropriate certification training program.

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