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EPA RMP citations @ a chemical and allied product merchant wholesaler facility (NAOH, HCL, C6H13N & $298K)

Respondent has a chemical and allied product merchant wholesalers process at the Facility, meeting the definition of “process”, as defined by 40 C.F.R. § 68.3. 35. Respondent is a wholesale chemical distributor that primarily repackages, stores, and distributes industrial chemical raw materials and allied products. Hydrochloric acid (36%) is an extremely hazardous substance within the…...

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Would stairs with an angle between 49 and 50 degrees and a tread depth of 9.5 inches (with 8 8-inch run and a nosing of 1.5 inches) comply with 1910.25?

Question: Would stairs built after January 17, 2017, be in compliance with 29 CFR 1910.25(c)(3) if they have an angle between 49 and 50 degrees and tread depth of 9.5 inches (with 8 inches run and a nosing of 1.5 inches) as shown in the below picture?… Membership Required You must be a member to...

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Can a PIT 3-year evaluation be done via a device such as a cell phone, tablet, or computer?

Background: 29 CFR 1910.178(l)(2)(iii) states: All operator training and evaluation shall be conducted by persons who have the knowledge, training, and experience to train powered industrial truck operators and evaluate their competence…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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OSHA answers two (2) PRCS questions related to the Isolation of Piping that does NOT terminate within the space

OSHA has addressed two (2) PRCS questions related to the Isolation of Piping that does NOT terminate within the space. This was a long time coming, as NFPA 350 and several trade groups have stated that piping that does NOT terminate within the PRCS need not be isolated. OSHA agreed, as long as six (6)…...

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US EPA issues citations for the CSB’s Reporting Rule (40 CFR Part 1604)

U.S. Environmental Protection Agency (EPA) and the U.S. Chemical Safety and Hazard Investigation Board (CSB) announced a settlement with an Electric Utility, resolving a violation of the Clean Air Act (CAA) and the CSB’s 2020 Accidental Release Reporting rule. This is the first time EPA has taken an enforcement action and reached a settlement with…...

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International Fuel Gas Code and NFPA 54 – Cap ALL outlets (2024)

Natural Gas is a hazardous material commonly found in nearly every structure in the USA. It is so abundant that many have lost respect for this highly flammable gas. I deal with NG nearly every month, either as a utility to appliances within a facility or as a “critical utility” to a PSM/RMP-covered process. Recently,…...

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Line Break gone bade (H2S)

At 10:00 p.m. on October 10, 2024, an employee (33) and a coworker, both boilermakers for a facilities support service, were working on a 12-inch pipe to flip the blind. The pipe released hydrogen sulfide gas, exposing the crew. The employee died from poisoning from the hydrogen sulfide gas…. Membership Required You must be a...

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PRCS Fatality (Cargo Tank/8% O2)

On the evening of 20 April 2022, the chemical tanker was anchored at anchorage 8 in the North Sea. The recently unloaded vessel had discharged its cargo ofpalm oil in Rotterdam, and was being prepared to take on a new cargo of gas oil in Amsterdam. To receive the new cargo, the tanks first had…...

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PRCS Fatality (Catylst Reactor/N2 Atmosphere/died from burns) w/ Video

Oxygen-containing air released from his breathing air helmet came into contact with the catalyst on top of him, causing it to ignite. On the morning of Friday, February 3, 2023, an employee of XXXXXX Service Catalyst Handling (the contractor) lost his life in an accident at the oil refinery. This happened while removing the catalyst…...

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Do we train personnel on our MOC program?

We have seen a significant decline in Process Safety over the past five years. It seems PSM was infected with COVID-19, and it has Long COVID-19 illness! In the past five years, we have battled facility management and corporate legal teams over one significant issue… Training personnel on the PSM/RMP Management of Change Program. All…...

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