As I said in my previous posts on GDC PSM citations, this is new territory for me and OSHA enforcement. I was always taught (and by some very sr. OSHA personnel) that OSHA can not use the GDC to enforce hazards for which OSHA already has a standard for. It was OSHA’s “carrot and stick” approach to PSM, stating that if a facility gets below the HHC’s PSM TQ, then it would not have to comply with PSM. But here we are in 2026, and we have the following:
- Check valve issues
- NH3 receiver had surface corrosion
- Piping had insulation and corrosion issues
- Ice build up on valves