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2016 Video of the Week #26 (Overhead Items are NEVER safe)

One of the top items from our process safety audits, PHAs, assessments, etc. is the lack of vehicle protection around critical equipment/infastructure.  Number one target in process plants is overhead piping!  It seems no matter how high we put it, it will get hit.  Already this year we were told that the pipe bridge over…...

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PSM/RMP Application and NFPA 704 Ratings

One of the top questions I receive is asking about how NFPA 704 ratings play into the application to OSHA’s Process Safety Management standard and EPA’s Risk Management Plan rule.  I hope to clarify any confusion this NFPA 704 application may be causing, as YES – the NFPA 704 does have a role in determining if…...

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EPA RMP Citations @ refinery (Flammables, Toxics & $165K)

Respondent owned and operated a refinery. On March 31-April3, 2014, EPA Region 6 conducted an unannounced, onsite CAA 40 C.F.R. Part 68 and Section 112(r) Partial Compliance Evaluation of the Facility. The refinery submitted a single RMP with covered processes that are subject to Program 3 requirements. The regulated flammable substances that are above the threshold…...

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UPDATE on OSHA’s PSM Revisions (June 2016)

OSHA has started its Small Business Advocacy Review Panel in order to get feedback on several potential revisions to OSHA’s Process Safety Management Program (PSM) standard.  The modernization topics OSHA is considering stem from industry best practices, inspection history, stakeholder comments received in response to OSHA’s 2013 Request for Information and lessons learned from accidents…...

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Accident Investigation Principles (DOE)

The basis for conducting any event investigation is to understand the organizational, cultural, or technical factors that, left unattended, could result in future accidents. Guiding concepts may be summarized as follows:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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OSHA PSM citations @ food additive manufacturer (Flammables & $180K)

A food additive manufacturer’s failure to handle hazardous materials and respond properly to an emergency led to an explosion that injured four workers, including two contractors who scaled an 8-foot security fence topped with triple-strand barbed wire to escape the fireball.  An OSHA investigation found the business violated process safety management procedures for the handling…...

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OSHA PSM citations @ cold storage facility (NH3 & $54K)

July 7, 2016 UPDATE – Company is Contesting all citations OSHA has issued nine serious safety violations to a food industry provider of cold storage warehousing and logistical services. A January 2016 complaint investigation found the company violated OSHA’s process safety management procedures for using ammonia in its refrigeration warehouse facility. An investigation by the…...

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Accident Causation Models

The Sequence of Events Model This is a simple, linear cause and effect model where accidents are seen as the natural culmination of a series of events or circumstances that occur in a specific and recognizable order. A chain often represents the model with a weak link or a series of falling dominos. This model…...

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EPA RMP Citations @ chemical manufacturing facility (Cyclohexylamine & $91,800)

Respondent owned and operated the a chemical manufacturing facility. On September 8-11, 2014, EPA Region 6 conducted an unannounced, onsite CAA 40 C.F.R. Part 68 and Section 112(r) Partial Compliance Evaluation of the Facility. The faility’s RMP lists three covered processes subject to Program 3 requirements. The regulated flammable substances that are held above the…...

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EPA RMP Citations @ utilities plant (NH3 & $37,500)

Respondent owns a Utilities Plant that maintains the support of steam, refrigeration, compressed air, cooling and process water; wastewater treatment, electricity, and natural gas for a chemical manufacturing complex. The Utilities Plant includes methanol storage and ammonia storage tank operations and distribution systems. Respondent produces, processes, stores, or handles up to a maximum of 51,180,000 pounds…...

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