Does your safety program have any safe work practices or does your Process Safety Management system have procedures with this requirement? It seems to be the fairly commonplace to require personnel to “have PPE available” for some critical tasks that can turn into an IDLH environment rather quickly. For those not familiar with this “practice”,…...
Inspect at least 4% of the total number of RMP-regulated facilities during FY 2014. Of these inspections, at least 36% should be conducted at high-risk RMP facilities, using the list derived from established high-risk criteria and provided by headquarters to regional offices at the beginning of the fiscal year. Regional program managers may, after consultation…...
The Risk Management Program (RMP) is implemented by the Office of Emergency Management (OEM) in EPA’s Office of Solid Waste and Emergency Response (OSWER). EPA and state and local implementing agencies conduct inspections at RMP facilities to determine compliance with RMP regulatory requirements, but because resources for conducting inspections are limited, within the past…...
This is an EXCELLENT presentation from EPA (4/2013) on doing RMP Inspections @ Ethanol Facilities. Although the presentation appears to be specifically for Ethanol facilities, it’s “suggestions and tips” WILL apply to any RMP covered facility (and for PSM-covered facilities as well). Some of the interesting revelations are: 1) EPA uses Google and Bing Satellite…...
This is why I have oh little faith in our government to protect us!!! Enforcement can NOT and should NOT be the driver behind improved environmental, health and safety performance! The hypocrisy in this report, aimed at the agency tasked with enforcing the very rule they wrote is nothing short of pathetic. Sitting here I…...
Does your process have any “underground piping”? We do not see this design in newer process designs, but in years past – putting pipe underground seemed like a good idea. This NTSB report does an excellent job of breaking down the failure modes of underground piping. The National Transportation Safety Board determined that the probable…...
An oldie but a goodie, showing how chlorine, with a VD>2.5 acts during a release (i.e. stays on the ground). On August 14, 2002, a chlorine transfer hose ruptured during a rail car (90 ton) unloading operation at a chlorine repackaging facility near Festus, Missouri. The hose rupture ultimately led to the release of 48,000…...
Another team of UNTRAINED, or TOTALLY IGNORANT but trained, workers doing their version of confined space entry. This is for those who provided negative comments on my other “entry photo”. This is good ole USA safety – NOT some third world country. And by the way, the workzone traffic management is a pathetic effort as…...
I was doing some research for as client and came across this information, which I think is something many of us have been struggling with. The source is MN-OSHA, which is a state OSHA plan and these plans can be MORE stringent than federal OSHA – but they can NOT be lesser. Which means that…...
This is a very interesting citation! OSHA issued citations to three (3) DIFFERENT organizations from the same inspection at a frozen foods plant. They cited the host company, a contractor who provides maintenance services for the refrigeration process, and the temp staffing agency that provided temp employees who worked in the plant. Not sure how…...
The Industrial Commission of Arizona (“Commission”) has received inquiries concerning a “Final Notice” document that has been received in the mail from the “Labor Standards Compliance Office” with an address of East Thistle Drive in Phoenix, Arizona. This document, believed to be a sales solicitation or advertisement, states that there is a fee of $295.00…....
Alaska’s Occupational Safety and Health Review commission hands downs a PRCS decision regarding a “Fish Bin Chiller Alley” at a seafood processing plant. A CSHO stated this corridor, meeting the criteria below, was not only a CS, but it was a PRCS: corridor approximately 60 feet long and 5 feet wide within the corridor there…...
