JZ and I got our ASSP Safety2019! reviews today, as well as the recorded sessions were made available last night. Some of those who sent me a not so nicely worded e-mail after the conference have since relistened to the session and a couple of them actually apologized. Although not all have decided I am […]
One of the weakness of OSHA’s PRCS standard(s) (1910.146 and 1926.1200) is that when the space is evaluated and it is determined to only be a Confined Space (CS). Too often we let down our guard and assumed the space will pose no hazards to the workers entering the space. Recently I was made aware
One of the more common misses by a lot of businesses, especially those using pressure vessels (PVs) in their PSM/RMP covered processes, is the “initial inspection” at the time of installation. We have discussed the “change of service” inspection several times; however, this inspection is for NEW PVs being installed. This requirement will certainly apply
Reminds me of the HFO-1234yf campaign with the “mildly flammable” from the new classification in ASHRAE 34. This one though goes a step further… LPG cylinders are not dangerous, their filled with safety.
One of the PSM/RMP safe work practices I try and get anyone who I cross paths with to implement on ALL of their hazardous materials (regardless of PSM/RMP applicability) is the Line Break and Equipment Opening procedure and permit process. Too often I learn of incidents in processes where the HHC/EHS was under the PSM/RMP
EPA recently announced its enforcement and compliance assurance priorities for fiscal years 2020 to 2023. There are seven (7) priority areas in total for this period, six of which are National Compliance Initiatives (NCIs), which will be led by EPA’s Office of Enforcement and Compliance Assurance. The one that I follow closely is…
Many facilities have been struggling with their in-house labeling to meet OSHA’s Global Harmonized Standard (GHS) labeling. I have written on this topic too many times to mention since 2015, but one thing that I am finding and I can not explain is how compressed gas manufacturers have not revised their “shipped container” labels to
Using “bailing wire” to hold open your deadman valves on oil-pots is a really bad idea… leaving the bailing-wire (e.g. evidence) on the valve after each use is just stupid and shows an auditor/inspector that this is an accepted and continual practice! Another tell-tale indication of cheating a deadman valve is the indentions left in
Respondent is a refrigerated warehousing and storage business which experienced a release of anhydrous ammonia on March 29, 2017 that resulted in a response from the local Fire and Rescue department. Following this event, the facility was requested to provide answers to a Chemical Release Questionnaire (CRQ) by EPA, pursuant to CERCLA § 104(e). Respondent’s
In the recent OSHRC decision where the ALJ decided that “tight-fitting” doors for an engine room/machinery room doors were not a PSM requirement since “doors” were not part of the covered process. What is confusing is that the company successfully convinced the ALJ that ASHRAE 15 was not their chosen RAGAGEP (even though they stated
With today’s announcement of the OSHRC decision that the IMC was the facilities RAGAGEP and that the IMC does not require detectors, I thought this record needs to be CORRECTED and CLARIFIED, as the ALJ’s understanding of how the IMC and its requirements apply to an ammonia refrigeration process/system. In the decision, the facility successfully
