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UPDATE on Chemical Facility Anti-Terrorism Standards Top-Screens and Security Vulnerability Assessments (SVA)

/ Chemical Process Safety (PSM/RMP), Free /

Earlier this year, the Department of Homeland Security (DHS) temporarily suspended the requirement to submit Chemical Facility Anti-Terrorism Standards Top-Screens and Security Vulnerability Assessments (SVA) in order to allow for a phased rollout of the new Chemical Security Assessment Tool (CSAT) 2.0 surveys and enhanced risk tiering methodology. On October 1, 2016, the requirement to…...

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EPA RMP Citations @ LPG Facility ( Propane, Butane, Ethyl Mercaptan & $154K w/ $154K SEP)

/ Free, PSM and RMP Citations/Analysis /

Respondent is the owner and operator of a facility which receives and stores liquefied petroleum gas (“LPG”) for wholesale customers. Respondent filed an RMP for the Facility with EPA, which was most recently updated on March 21, 2013 and identified a covered LPG storage process at the Facility subject to Program 3 requirements, with specified…...

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EPA RMP Citations @ Pharmaceutical Facility (Aqueous NH3 & Methylamine Gas; $190K and lowering inventories)

/ Free, PSM and RMP Citations/Analysis /

Respondent is the owner and/or operator of a pharmaceutical manufacturing facility which uses ammonia (conc. 20% or greater) (“aqueous ammonia”) and methylamine gas in two (2) processes for the manufacture of pharmaceuticals. EPA conducted an inspection of the Facility on or about January 31 , 2014 to assess compliance with 40 C.F.R. Part 68. Respondent subsequently…...

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OSHA’s Standards Improvement Project, Proposed Revisions (October 2016)

/ Free, OSHA Compliance /

As part of an ongoing effort to revise provisions in its standards that may be confusing, outdated or unnecessary, the Occupational Safety and Health Administration is proposing 18 changes to the agency’s recordkeeping, general industry, maritime and construction standards.  The proposed revisions would save employers an estimated $3.2 million per year. They are based on…...

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OSHA issues citations for not protecting Propane Tank and Cylinder area

/ Free, OSHA Compliance /

Recently OSHA issued citations to a business that has its own LPG storage tank and fills its own forklift LPG cylinders.  We have seen far too many of these types of set-ups that are FAR OUTSIDE any resemblance of OSHA/NFPA/Fire Code compliance.  These two (2) citations drive home the point about PROTECTING our storage tanks from…...

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Safety and Health Program Assessment Worksheet (HI-OSHA)

/ Free, OSHA Compliance /

Another great OSHA State Plan resource; this time from Hawaii.  This is an excellent self-evaluation worksheet that covers pretty much all facets of a traditional occupational safety and health program/process.  If a business uses this tool to its full advantage, this assessment can paint a pretty accurate picture of the state of their S&H program efforts…....

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NC-OSHA provides some EXCELLENT ppt’s for FREE

/ Free, OSHA Compliance /

The state of North Carolina’s OSHA has updated many of their powerpoint presentations this year, with more coming soon.  Here is the list of ppt’s currently available:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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2016 Video of the Week #40 (The Power of Chemical Reactions)

/ Free, Video of the Week /

Now you see it… Now you don’t!  Watch a DOT 412 Trailer disappear before your eyes and no it is NOT a magic trick!  It is imperative to properly follow the Hazardous Materials Regulations. Improperly shipped hazardous materials can sometimes end with a catastrophic failure. In this case, a corrosive material was placed in an…...

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Senator Boxer (D-CA) sends letter to EPA calling on the agency to strengthen their RMP revisions

/ Chemical Process Safety (PSM/RMP), Free /

This week Senator Barbara Boxer (D-CA), Ranking Member of the Environment and Public Works Committee, sent a letter to the Environmental Protection Agency (EPA) calling on the agency to strengthen the proposed revisions to the Risk Management Plan rule. Specifically, she wants the following prevention requirements added to the rule before it is finalized (apparently…...

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More OSHA compliance data – OSHA 2015 Citations by NAICS Industry Sectors

/ Free, OSHA Compliance /

It seems many of you are hungry for OSHA inspection/enforcement data, so here is my next installment.  In this XCEL Spread sheet I have taken the industries I spent the most time in during 2015 and listed all the OSHA citations for these industries.  I have taken the liberty to break out the Top 10…...

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OSHA issues citations for NH3 Refrigeration Fatality ($173K; seafood processing business)

/ Free, OSHA Compliance /

UPDATE:  OSHA Settlement (Final) This week OSHA posted their citations (20 serious and 1 “other-than”) for a fatality involving Anhydrous Ammonia (NH3) at a seafood processing business in Boston, MA.  None of the citations were for 1910.119 (PSM) indicating that the process contained less than 10,000 pounds of NH3.  However, OSHA did issue two (2)…...

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