NH3 Refrigeration GDC citation
Not having an ammonia detection system, which had been cited the previous year, also as a GDC; however, it seems the business was sold, and the new owner was cited for not addressing the detection system.
Another PSM GDC citation in NH3 Refrigeration
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”
Can OSHA issue 5(a)(1) citations when a process is under its PSM TQ?
Apparently, they can and have. Here are some GDC citations for an NH3 refrigeration process. These were part of a large release inspection that included some HAZWOPER and HAZCOM citations. My only guess is that these GDC citations are tied directly to the NH3 release, but I have not yet seen the field notes, so
NFPA updates its 704, Standard System for the Identification of the Hazards of Materials for Emergency Response
The 2027 edition of the standard includes new definitions for the terms battery energy storage system and lithium-based battery with associated annex material. Updates have been made in Section 6.2 to align with NFPA 1 regarding 1A and 1B flammable gases and to further clarify that Category 1B has a lower flammability than Category 1A
What is a Hierarchy of Controls Analysis (HCA)?
A Hierarchy of Controls Analysis (HCA) is a highly structured risk-mitigation methodology. It is specifically required under CalARP Program 4, which applies to petroleum refineries operating within California. While a standard Process Hazard Analysis (PHA) identifies risks and lists existing safeguards, an HCA forces a facility to systematically evaluate whether hazards can be eliminated or
What is a Safer Technologies and Alternatives Analysis (STAA)?
A Safer Technologies and Alternatives Analysis (STAA) is a systematic risk management evaluation used in process safety engineering to identify and assess ways to make a process inherently safer. Instead of relying solely on add-on safety equipment or administrative procedures to manage a hazard, an STAA asks: Can we eliminate or significantly reduce the hazard
What is OSHA proposing to change in the respiratory protection program?
OSHA is proposing several updates to its Respiratory Protection Standard (29 CFR 1910.134) as part of a broader deregulatory effort to reduce employer compliance costs and provide greater flexibility, without compromising worker safety. Here are the key changes currently on the table:
EPA RMP citations @ food facility (NH3 & $33K)
Respondent is the owner and/or operator of the Facility, which is a “stationary source” and has registered an RMPlan with the EPA for its Facility and has developed an RMProgram accidental release prevention program for the Facility. At its Facility:(a) Respondent operates an ammonia refrigeration plant.(b) At all times relevant to the violations alleged, Respondent
EPA RMP citations @ food facility (NH3 & $160K)
At all times relevant to this CAFO, Respondent operated a facility that utilizes anhydrous ammonia to produce approximately one-quarter billion frozen burritos for distribution nationwide each year. On July 20, 2022, EPA performed an inspection of the Facility to evaluate compliance with the CERCLA Section 103, EPCRA Sections 304-312, and CAA Section 112(r). Based upon
It ALL starts here for management… ANSI/ASSE Z590.2-2003
Yes, this is a very OLD standard, but there is really nothing to replace it, as it still holds true today as much as it did in 2003. I have discussed this standard several times, and I ALWAYS share it with clients who are a tad lost on what the role of their safety professional(s)
3 executives receive 2-years in prison for the death of a worker in a 2019 fire; two of those being prosecuted were “risk prevention technicians”
SAFTENG NOTE 1: Two (2) of those being prosecuted were risk prevention technicians; one was a company employee, and one was a contractor SAFTENG NOTE 2: This silo explosion is very similar to the recent silo explosion in ME that took the life of a Firefighter Three (3) executives from an industrial wood processing and
Is a Tanker Truck a “shipped container” under OSHA’s GHS/HAZCOM?
If we look closely at this ISO container, specifically between the two (2) placards, we will see a laminated GHS label with the product identifier, pictogram(s), signal word, manufacturer’s name, and phone number. But is that middle label required on this ISO container?