2015 Photo of the Week #41 (1 step ladder, 1 extension ladder, and 6′ of rope = what could possibly go wrong)
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2015 Video of the Week #41 (Power of a SCBA Cylinder)
This is an old steel 2216 psi cylinder! Today’s fiber wrapped cylinders are HIGHER PRESSURE and weigh less so the response would be more than seen in this video. SCBA Inspections and Hydro static Testing are KEY to ensuring a SAFE CYLINDER…. Membership Required You must be a member to access this content.View Membership LevelsAlready...
Does ammonia need to be removed from evaporative condenser coils for entry into these PRCSs??
7/7/2020 UPDATE: Found the OSHA Case where an evaporator fan motor bracket failed, causing the fan to fall onto the coil(s) and cause a NH3 release 6/30/2020 UPDATE: See my video of an NH3 Condenser Tube/Coil failure (Hydraulic Expansion) on my YouTube Channel In 2012 I attempted to convince you that ammonia evaporative condensers…...
What it looks like to go from a Level 2 RMP to a Level 3 RMP
The recent change in OSHA’s PSM definition of a “retail facility” is having a large ripple effect all the way across EPA’s RMP rule. As I wrote about in “How does OSHA’s revised PSM “retail exemption” policy impact my RMP?” this change, thought by many as minor – thus the six-month compliance window for these…...
EPA RMP citations @ grocer for delayed reporting of ammonia release, risk management, and emergency planning violations ($110K w/ $180K SEP)
A grocer has settled with EPA for alleged chemical release reporting, risk management, and emergency planning violations at its warehouse facility in Seattle, Washington and will pay EPA a $110,200 penalty. The company will also complete a Supplemental Environmental Project which includes ammonia release detection improvements valued at over $180,000. The facility is a distribution…...
OSHA’s REVISED Field Operations Manual (FOM ) incorporates “employer safety incentive” programs directly into the inspection process
So many of us can recall the 2012 “Letter to Regional Admins” titled Employer Safety Incentive and Disincentive Policies and Practices where OSHA called out “safety incentive” programs that encourage under reporting of accidents. Then it was merely a “letter” to regional admin(s). Now the Field Operations Manual (FOM) has been revised in a manner that…...
MARPLOT 5.0.2 is now available for download
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OSHA publishes Confined Spaces: Protecting Construction Workers in Confined Spaces – Small Entity Compliance Guide (OSHA 3825)
This guide is intended to help small businesses comply with the Confined Spaces standard. It addresses the most common compliance issues that employers will face and provides sufficient detail to serve as a useful compliance guide. It does not, however, describe all provisions of the standard or alter the compliance responsibilities set forth in the…...
Comparing EPA’s RMP Level 2 to Level 3 Programs
Comparing RMP Level 2 to Level 3 Programs RMP Program Level 2 RMP Program Level 3 §68.48 Safety information (a) The owner or operator shall compile and maintain the following up-to-date safety information related to the regulated substances, processes, and equipment: (1) Material Safety Data Sheets that meet the requirements of 29 CFR 1910.1200(g); (2) Maximum…...
OSHA’s Top 10 Citations for FY 2015
This list was released at last week’s National Safety Council‘s 2015 Congress & Expo. OSHA’s Top 10 for FY 2015 (10/1/2014 through 9/8/2015) are: Fall Protection (1926.501) – 6,721 violations Hazard Communication (1910.1200) – 5,192 Scaffolding (1926.451) – 4,295 Respiratory Protection (1910.134) – 3,305 Lockout/Tagout (1910.147) – 3,002 Powered Industrial Trucks (1910.178) – 2,760 Ladders…...
The process of isolating a PRCS
Lets walk through a process in which we will isolate a PRCS using either the blinding/blanking or disconnect and misalignment provisions. The vessel we will enter is a PSM/RMP covered piece of equipment. Here’s how I was taught the process works… Since this is a PSM/RMP covered process we will be impacted by three key…...
When is entry rescue required and when is non-entry rescue required for entries into Permit-Required Confined Spaces
UPDATED 10/5/15, see bottom of page Another common debate we like to have among our profession… When is entry rescue required, and when is non-entry rescue required for entries into Permit-Required Confined Spaces? Ask ten safety professionals who are really into PRCS safety, and I will bet you a burger and a beer that we…...