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OSHA machine guarding citations to steel fabrication facility and its staffing company (multi-employer citation OSHRC)

The staffing company contests a two-item Citation and Notification of Penalty (Citation) issued March 20, 2017, by the Secretary. The Secretary issued the Citation following an inspection by OSHA on November 21, 2016, of a steel fabrication facility, in response to a report of a serious employee injury.  The injured employee was one of several…...

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How do you update your RMP Emergency Contact info within a month when a replacement contact is not in place within one month?

Pursuant to the risk management program regulations, the owner or operator of a regulated stationary source is required to submit a correction within one month of any change in the emergency contact information (40 CFR §68.195(b)). What should the owner or operator do for the required correction if they do not have a replacement contact…...

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EPA RMP citations @ unmanned gas processing plant (Flammables & $29K)

Respondent operates a an unmanned gas processing plant that has on-site for storage, 154,110 pounds of flammable mixture. The process is a RMProgram level 2 covered process, which stores or otherwise uses a flammable mixture in an amount exceeding its applicable threshold of 10,000 pounds. On April 23, 2014, the EPA contractor conducted an on-site…...

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Can employee’s be fit-tested with “stubble beard growth”?

This is without a doubt one of the top ten questions we get each year… Can employee’s be fit-tested with facial hair stubble?  And not to be a smart a_s about it, the answer is still the same… NO.  OSHA has been consistent over the years and my dozen or so articles on the matter…...

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Is instruction on donning a respirator during fit-testing count as the “annual training”?

As safety departments get squeezed for $, we are seeing a spike in a severe deficiency in a site’s respiratory protection training.  I first got wind of this when a client I was scheduled to do some respiratory protection training for canceled the course.  This is a client we provide other services for, so while…...

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OSHA issues PRCS citations after an explosion on a tow boat

OSHA has cited five contractors for safety and health violations after three employees were fatally injured and two others critically injured following an explosion onboard a towboat in Kentucky. The five companies collectively received 55 of violations with proposed penalties totaling $795,254.  OSHA cited a ship repair contractor, an insulation contractor, two temporary staffing companies…...

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Can OSHA require abatement when no citation has been issued? (OSHRC and enterprise-wide abatement)

As some of you may recall the Post Office got hammered by OSHA some years ago, and from those inspections, OSHA asked for abatement across all post office locations.  One of those items was related to heat stress, and I might add that already this summer we have seen another heat stroke fatality within the…...

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Are your LOTO “machine specific” procedure actually “specific” and the OSHRC settles the debate about isolating a PRCS

This 2018 decision is a MUST read for all safety professionals who wish to question the requirement for “machine specific” isolation procedures for “complex processes” AND for those who want to understand the isolation expectation for entry into a PRCS.  This business made two mistakes that run rampant in businesses when it comes to the…...

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Anhydrous Ammonia will BURN! (Video)

WARNING!  NEVER, in your wildest dreams, EVER EVER do this!!!!  But this video does show us the flammable properties of ammonia gas.  Crazy I tell ya, just crazy – not to mention this is just NOT the way Hot Work was intended to be carried.  SO MANY concerns – but I just wanted to demonstrate…...

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“Slugging” Compressor with liquid ammonia (Video)

 This is a telling video, showing us the consequences of “slugging a compressor” with liquid anhydrous ammonia.  I do not have the details of the event, but one would have to consider the cause being a “High Level” in the vessel the compressor is intending to pull vapor from.  These vessels should have level control…...

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Line Break Gone Bad (tetra-methyl ammonium hydroxide and man-lift)

At 4:45 p.m. on December 27, 2017, an employee was adding piping from a man-lift to a chemical tank when he struck a transducer on a nearby chemical tank containing tetra-methyl ammonium hydroxide. The employee was drenched and was able to lower the man-lift and get into the emergency wash station. Several co-workers assisted the…...

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