Bryan Haywood

Is OSHA Targeting Ammonia Refrigeration & Chlorine water treatment processes in their new PSM NEP?

UPDATE from my OSHA contacts:  The NEP was written so that OSHA offices would not single out NH3 refrigeration and CL2 water treatment processes.  OSHA feared that since these processes were so plentiful that they would target these types of processes and not inspect other types of processes, so in reality they were spelled out […]

PPE payment for static dissipative safety-toe footwear

Scenario: An employer requires ordinary safety-toe footwear throughout their facilities and pays for the first $100 of the footwear cost. As part of a recent company-wide static electricity control program, employees working with flammable liquids and products are now required to have static dissipative safety-toe footwear.   Question 1: Would the static dissipative safety-toe footwear

Summary and Explanation of Revisions to the Acetylene Standard as it applies to cylinders

This NPRM would update the SDO standards referenced in the three paragraphs that comprise the Acetylene Standard. The Compressed Gas Association (CGA) published several editions of these SDO standards after OSHA adopted them in 1974, and one of these standards (i.e., Compressed Gas Association Pamphlet G-1.4-1966), is no longer available for purchase from CGA. Therefore,

EPA’s General Duty Clause for RMP

Yes, EPA has a General Duty Clause for RMP, much like OSHA’s General Duty Clause.  However, EPA’s is much more detail.  This month I came across a facility that used to be a RMP/PSM covered facility, but after much work they lowered their quantities below the RMP/PSM Thresholds.  Once this was done, they literally threw

More on EPA’s General Duty Clause

I have had tons of questions and comments on last week’s article regarding EPA’s General Duty Clause as it relates to RMP Listed chemicals (e.g. Extremely Hazardous Substances) and the requirements for employers, EVEN if they were below the RMP Threshold.  As EPA states in one of their Fact Sheets on the GDC…It is important

Top 10 RMP Chemicals by On-Site Quantities

Top 10 RMP Chemicals by On-Site Quantities This table shows amounts of each chemical within processes that have worst-case accidents that could potentially reach off-site. Facilities that are no longer registered with RMP are not included. Chemical Name Chemical Type # of facilities Pounds in processes Ammonia (anhydrous) Toxic 7,672 182,886,947,607 Flammable Mixture Flammable 669

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