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EPA RMP Citations @ organic chemical manufacturer (Phosgene & $40K; w/ SEP of $99K)

Respondent is the owner and/or operator of a manufacturing facility located in New York. The Facility uses phosgene in a process for the manufacture of organic chemicals. Respondent filed an RMP for the Facility with EPA on or about May 14, 2009, that, among other things, identified a covered phosgene process at the Facility subject…...

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EPA RMP Citations @ Fertilizer Facility (NH3 & $16K w/ a SEP of $4K)

Respondent owns and operates the bulk anhydrous ammonia storage facility located in Nebraska. On or about August 18, 2014, EPA conducted an inspection of Respondent’s Facility to determine compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68. Information gathered during the EPA inspection revealed that Respondent had greater than 10,000 pounds of…...

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OSHA issues PRCS citations @ transformer manufacturer ($43K; 2 fatalities – 1 entrant and 2 “would be rescuers”)

Many of you that followed my incident alerts may remember the transformer manufacturer that had a fatal PRCS accident that killed two workers and left a third injured back at the end of 2015. The three people were working on a transformer in the plant and were found unresponsive. Unofficial sources said the transformer was…...

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OSHA Citation Analysis for PSM, LOTO, PRCS (2015)

My postings back in January were so popular I decided to put the data into EXCEL spreadsheets so that you all can play with the data as you see fit.  I only did PSM (1910.119), Permit-Required Confined Spaces (1910.146), and Control of Hazardous Energy (LOTO 1910.147).  Each workbook contains three (3) worksheets: 1) By #…...

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ALOHA® – Guidebook with Example Scenarios (September 2016)

The National Oceanic and Atmospheric Administration, Office of Response and Restoration and the U.S. Environmental Protection Agency, Office of Emergency Management has published this EXCELLENT guidebook which contains three (3) step-by-step fictional ALOHA example scenarios. You can complete the first two scenarios using only ALOHA. To complete the third scenario, you’ll also need the latest MARPLOT…...

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WA-OSHA has published their DRAFT – Confined Spaces in Construction and it is AWESOME

The state of Washington’s OSHA has published their DRAFT standard on Confined Spaces.  The standard pretty closely mirrors federal OSHA’s 1926.1201-.1213; however, the OSHA standards in WA must be written in a much more simplified manner, thus we end up with a standard that is easier to read and WA-OSHA does an EXCELLENT job explaining…...

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OSHA loses their battle to redefine “retail” in the PSM Standard (1910.119)

Friday morning (9/23/16) the United States Court of Appeals, For the DISTRICT OF COLUMBIA CIRCUIT announced that OSHA could not redefine “retail” using a Letter of Interpretation (LOI) or Memorandum, OSHA would have to go through the Notice of Public Rule Making (NPRM) in order to redefine the term.  Ironically, it was a 1995 LOI that actually…...

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2016 Photo of the Week #38 (Compactor… “no one would ever crawl in there”)

This week I am pulling a double whammy on guarding (Video of the week is a foot amputation in an auger).  These days there are few work places that do not have this type of compactor for their “recycling” programs.  This equipment is CLEARLY a PRCS, albeit one that can be easily reclassified.  But as…...

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2016 Video of the Week #38 (Foot Amputation – Guarding/HMI)

WARNING VIEWER Discretion Advised – this video may be upsetting to some viewers as it shows the painstaking mistake a worker makes by using his foot to push material into a feed auger.  In this video we can see the worker standing in the “dump chute” manually feeding material into an auger hopper.  It appears…...

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