That is PSM lingo for…when you are utilizing Risk Based Inspection (RBI) protocols and you wish to extend the inspection or PM frequencies on a piece of covered equipment, this is without a doubt a change that REQUIRES an MOC.
Following the Buncefield incident the importance of preventing loss of containment from bulk storage tanks has come to the fore. A significant factor in ensuring contained fluids are not accidentally released is the continuing mechanical integrity of the tank structure. http://www.hse.gov.uk/research/rrhtm/rr760.htm
OK, PSM requires us to evaluate our “contractors” who will be working on, in or adjacent to a covered process. OSHA’s Permit Required Confined Space Standard also comes into play during a PSM audit (see .119(f)(4)). Under the PRCS std. OSHA requires us to “evaluate” our rescue services (.146(k)(1)(i)-(ii)) using something similar to Appendix F
We always get the answer…”We do not have any temporary operations,” so that does not apply to us. A good auditor will educate the site personnel by taking them out to the field and finding a bypass around a control device. Then, we will ask for the “procedure” that is used when the bypass is
Often we see facilities viewing MOC and PSSR’s management systems as DUPLICATIVE efforts. There is a distinct difference between these two PSM/RMP requirements. Basically, this is how it was so explained to me by Russ Evanston, one of the founding fathers of PSM.
OSHA and EPA are now citing for not doing MOCs on personnel changes! The debate rages on for those living in the PSM/RMP world. Just this week, a client called me to help them with an audit finding they received in a third-party audit. The auditor wrote the finding that they were not considering personnel
Well I told you last week that I would scare the !@#$ out of a lot of you, so here it goes. Nitrogen can be your ignition source if it is NOT applied and used properly.
I have always said that 90% of establishing a safety culture is communication of safety ideas and information. Safety is competing for the minds of all workers to THINK about SAFETY in all that they do. We are competing with Quality, Production, Costs Control, Family, etc. in the thoughts of our workers. A lot of
There is a lot of confusion on reclassifying Permit-Required Confined Spaces to Non-Permit Spaces, which is allowed on spaces with NO KNOWN or POTENTIAL hazardous atmospheres. 1910.146(c)(7) covers this practice. The key DIFFERENCE between “reclassifying” a space using section (c)(7) and using “alternative entry methods,” which is covered under section (c)(5) is ELIMINATION vs. CONTROL.
Many THANKS to my NEW & RENEWING Corporate Partners in Safety! since 2007 since 2011 since 2009 since 2/11 2011 Fatality Tracker Electrical 6 (2010 = 90) (2009 = 100) Forklift/Manlift Mobile Equipment 27 (2010 = 110) (2009=88) Mining 43 (2010 = 480) (2009 = 586) Explosions 48 (2010 = 246) (2009 = 302) Cranes
“Never saddle a dead horse” means that when using your Crosby clips, the “U Bolt” is ALWAYS over the DEAD part of the cable and NEVER on the part of the cable that will see the load applied to it. In other words, NEVER have the u-bolt over the load side of the cable. Here
“Recognized And Generally Accepted Good Engineering Practice” (RAGAGEP) – are engineering, operation, or maintenance activities based on established codes, standards, published technical reports or recommended practices (RP) or a similar document. RAGAGEPs detail generally approved ways to perform specific engineering, inspection or mechanical integrity activities, such as fabricating a vessel, inspecting a storage tank, or
