Many hot work operations are performed by outside contractors, these include cutting, welding, joint soldering, paint removal, reroofing, etc. The tendency is to relax rigid procedures for contractors assuming they know their jobs. However, this practice has produced a discouraging loss history. Hot work by itself is a hazardous process. When outside contractors are involved,…...
Last week the CSB announce a public meeting regarding the refinery accident in CA back in February. In their announcement the CSB informed us that following the staff presentation, the Board will hear an update on the new process safety management reforms in California from a panel of experts. I have written about these PROPOSED changes…...
The Respondent is poultry processing business. On April 14-15, 2015, EPA conducted a compliance inspection of the Respondent’s facility to determine compliance with the Risk Management Plan (RMP) regulations promulgated at 40 C.F.R. Part 68 under Section 112(r) of the CAA. The EPA found that the Respondent had violated regulations implementing Section 112(r) of the CAA…...
I am sorry, but with six crashes and dozens of hack attempts from within the website, I can not leave the doors open any longer. So I decided to go back to the 1990 days when SAFTENG was free to working professionals who wanted access to safety material. Anyone with a VALID business e-mail address…...
OSHA’s Permit Required Confined Space standard has been around since the mid 1990’s and the requirement(s) to perform “program reviews” has been part of the standard from its very beginning. In a recent OSHRC case, both the Administrative Law Judge and the full commission took issue with a company’s efforts in how they did (or…...
This is my last article in my series regarding excess flow valves. I haveattempted to explain how these devices can aid in controlling a significant leak, as well as how these valves get abused in their design and maintenance. As I have stated before, these valves should NOT be considered a “safeguard” in our PHA’s until we have…...
This OSHRC decision reverses an ALJ decision which I posted in August 2013, but this case has some very interesting aspects that EVERYONE who manages a PRCS Entry program needs to read. Most notably, this case involves: gas meter maintenance, program revision/employees not protected, “Conditions” Required for Alternate Entry, program revision/annual permit review, enforcement,…...
The Pipeline and Hazardous Materials Safety Administration (PHMSA) is seeking to update requirements covering the use of excess flow valves in natural gas distribution pipelines. In its November 30, 2015 Federal Register notice, PHMSA announced its Gas Pipeline Advisory Committee will meet to consider and vote on a rulemaking proposal that expands requirements for excess…...
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On July 25, 2014, EPA conducted a compliance inspection to determine its compliance with the Risk Management Plan (“RMP”) regulations promulgated pursuant to Section 112(r) of the Act, and set forth at 40 C.F.R. Part 68. Based on the July 25, 2014 inspection and documents submitted by Respondent, EPA has determined that Respondent violated the…...
I should point out that this facility was found to be OVER the threshold for 180 days over a three (3) year period. EPA went through paper work to find times the facility had over 10,000 pounds of a NFPA “4” flammable mixture in their process. The process involves dissolving acetylene in acetone in order…...
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