How many Confined Spaces do you see? How many Confined Spaces signs would you use? PLEASE note that without knowing the hazards of these Confined Spaces, I chose to call them only Confined Spaces rather than Permit-Required Confined Spaces. CS’s are NOT required to be labeled, but PRCSs are REQUIRED to be labeled, except under…...
EPA conducted an inspection of the Facility on December 4, 2012. The Inspection was conducted to determine the Facility’s compliance with Sections 112(r)(7) and 112(r)(1) of the CAA, the RMP accident prevention program and the General Duty Clause, respectively. At the time of the Inspection, Respondent had designated the Facility as an RMP Program Level…...
OSHA is REVISING the electrical safety-related work practices standard for general industry and the electric power generation, transmission, and distribution standards for general industry and construction to provide additional clarification regarding the applicability of the standards to certain operations, including some tree trimming work that is performed near (but that is not on or directly…...
As we are now 20+ years into the PSM standard (16 years for RMP) I think it may be time to revisit the reason for these standards and what OSHA and EPA are trying to drive us to achieve and how our HHC/EHS inventory management plays a HUGE role in this effort. This MII requirement…...
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You and your team are preparing to enter a PRCS, and as the entry supervisor begins to review the permit, he/she explains the space is isolated, and you notice the permit states “LOTO- N/A.” You inquire about this and ask about the isolation method(s) used for the entry. The supervisor offers to show you the…...
Have you ever wondered why PSM and RMP require an employer to establish safe upper and lower limits for such items as temperatures, pressures, flows, or compositions in their Process Safety Information and evaluate the consequences of deviating from these limits, including those affecting the safety and health of employees? And then, in the Operating…...
Current Policy PHMSA supports a practice of no gaps/no overlaps. PHMSA has not changed its policy or inspection approach toward processing facilities. PHMSA has no interest in regulating processing units. OSHA regulates gas processing units. PHMSA and OSHA are in agreement on jurisdictional lines. Neither PHMSA or OSHA are limited by fence lines CLICK HERE…...
Respondent owns and operates a potato processing facility which is located, according to the U.S. Census data from 2010, from a few thousand people who live near the Facility. The Facility is located within 0.25 miles of Route 1 and 0.5 miles from the downtown area. Respondent uses anhydrous ammonia in a refrigeration process (“the…...
Questions and Answers from PSM Webinar Sept. 29, 2015. Answers provided by Jeff Wanko, PE, CSP, and Safety Engineer in OSHA’s Directorate of Enforcement, Office of Chemical Process Safety in Washington, D.C. Q. Do you have to test the safety equipment annually? A. Under paragraph (j), mechanical integrity, OSHA requires that employers inspect and test process equipment…...
An OSHA inspection identified several serious and recurring deficiencies in the company’s Process Safety Management program. As a result of these conditions, OSHA cited the facility, the nation’s leading propane supplier, on Sept. 24, 2015, for three repeated and five serious violations of workplace safety and health standards. Proposed fines total $135,000. OSHA found the…...
