This is another part of my recent respirator articles; my attempt to help up-and-coming program administrators understand what OSHA is actually requiring as the absolute minimums. This post is about the “numbers” we see and hear when discussing respiratory protection. As I posted a few months ago, during an audit for a client, we came…...
A couple of weeks ago EPA met the court’s decision by posting the amended RMP rule on the CFR. This meant that those amendments that had dates that had come due were in full play. But on May 30, 2018, EPA proposed changes to the final RMP Amendments rule issued on January 13, 2017. EPA…...
If I had a dime for everytime someone says to me… “where do you come up with all this sh_t?” during our deep discussions on process safety topics. And whenever I do my 5-day Process Safety course we seem to always get deep into the “process safety weeds” and one topic that many students are…...
ATTENTION FOOD PROCESSOR CLIENTS: OSHA is onto the Clean-In-Place (CIP) process and how it contains “hazardous energy sources”, which in turn makes opening up the CIP system a “line-break” and LOTO activity. These citations center around PPE and LOTO issues at a food plant where workers were exposed to “hot water”. OSHA has cited a…...
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I have so many of these incidents on video, investigation pics, investigation reports, OSHA citations, and yet the video’s, pics and reports continue to arrive in my in-box. This one is quite something, but even after that awesome display of a flash fire exiting a manway like a rocket – anyone want to bet me…...
SAFTENG members, here are four ppt files that I used at my four-part series I did the past four months at the SW OH ASSP Chapter meetings. We broke the sessions down into: Evaluating spaces What makes a space a CS What makes a CS a PRCS Entry options (c)(5) Alternative Entry (c)(7) Reclassification (d)-(k)…...
Yes, as I posted a couple of weeks ago, the RMP Amendments are now in effect (at least those with compliances dates that have passed – some have dates further out). One such requirement that seems to be causing a stir is “3rd Party Audits” for Program 2 and 3 Level RMP processes (e.g. 68.59…...
In this last part of 2018, I have been on a LOTO crusade; I have been to 12 different facilities since August to help them understand LOTO. Some projects were complete new builds, some were to help with implementing Group LOTO, and a few were to training company safety professionals on the OSHA requirements so…...
UPDATE: Earlier this year I posted a news account of an NH3 release in Cincinnati because of statements from a VP of the company stating an “explosion had occured”. I have since learned that yes it was an “explosion”, but not one involving fire as so many think of when they hear that word. From…...
Inspection of buried process piping is different from above ground process piping because significant external deterioration can be caused by corrosive soil conditions and the inspection is much more difficult due to the inaccessibility of the piping. However, as difficult as it may be, buried piping MUST be inspected to determine its external surface condition…....
I was recently reminded of how so many in process safety struggle to see their process(s) thru different lenses based on the piping’s life cycles. Using ASME B31.3 and 31.5, we see that these codes (e.g. RAGAGEPs) are design and build piping standards. Looking at API 570 series we see these are codes (RAGAGEPs) for…...
