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2018 Video of the Week #14 (When a chock would have saved the day!)

This week’s video shows us the importance of “chocking” when we are loading/Unloading hazardous materials.  I am not quite sure what happened, other than it appears the parking brake failed or was not set (although it appears it failed again after the first attempt to stop the truck).  But a simple “chock” would have saved…...

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EPA withdraws it’s Reportable Quantity Modifications NPRM

On 3/28/2016, for reasons unknown, the EPA withdrew its notice of proposed rulemaking (NPRM) at the Office of Information and Regulatory Affairs (OIRA) regarding possible modifications to reportable quantities. The NPRM was submitted on 3/6/2018. … Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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New Safety Data Sheets (SDS) and referenced RAGAGEPs

Recently I was working with one of my flammable liquid clients who recently hired some new engineers who needed some flammable liquids training.  During my 1-day “Flammable Liquids 101” course we touch on those flammable liquids that are “non-conductive,” and as usual this caused quite a stir among the attendees.  Most of the attendees, including…...

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EPA RMP citations @ WWTP (Cl2 & $10K w/ $64K SEPs)

Respondent is a municipality in the state of Nebraska, which owns and operates a Water Treatment Plant.   Information gathered during the EPA inspection revealed that Respondent had greater than 2,500 pounds of chlorine in a process at its facility.  From the time Respondent first had on site greater than 2,500 pounds of chlorine in a…...

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How many RMPs do you have vs. How many processes you report in your single RMP

This topic is a bit off, but for some reason, this issue is trending in our RMP/PSM audit findings.  We have been finding this since we began performing RMP audits in the 2002-2003 time frame, but the numbers are trending up.  Now, this is NOT about a “hazardous condition,” but in almost all our cases,…...

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There is a difference in labels on “shipped containers” and “workplace labeling”

I am guessing we may be having this debate for the next 20-30 years, as before OSHA revised their HAZCOM standard to the Globally Harmonized version we were still debating the requirements of the original HAZCOM standard up to the day it got changed (e.g., 30+years).  But it seems there are companies benefiting from the…...

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OSHA Safety for Public Sector Highlights of Updated Law M.G.L. c149 §6½

On March 9, 2018, Governor Baker signed a bill that amends M.G.L. chapter 149 §6 ½. The law was updated to clarify employee safety requirements in public sector workplaces and is enforced by the Department of Labor Standards (DLS).  Highlights:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member?...

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OSHA issued PRCS citations in fatal grain bin engulfment

Citation 1 Item 1a Type of Violation: Serious; $2,500 IAC 875 – Chapter 10 1910.147(c)(4)(i): Procedures were not developed, documented and utilized for the control of potentially hazardous energy when employees were engaged in activities covered by this section: (a) Waterloo Facility – The employer did not establish lockout specific procedures for this location. Employees…...

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Hazardous Area Ventilation “make-up air”

In my line of work, I come across a lot of areas that have a “ventilation system” that intends to reduce exposure and control flammable gases/vapors.  The vast majority of these systems are “sized” properly, meaning they move enough air to meet the code/standard they were built to; however, one aspect of the system we…...

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Relief Valve Testing and the National Board

Recently I posted an article about the IIAR’s new Maintenance Standard that was going to allow bench testing of a “sampling” of our Relief Valves (RVs) as an alternative to the 5-year cycle.  I have written numerous times about this practice, but I could never compete with the National Board’s article(s) on the topic.  Their…...

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