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OSHA’s new Fact Sheet on PRCS Rescue – Is 911 your Confined Space Rescue Plan?

Permit-required confined spaces can present conditions that are immediately dangerous to workers’ lives or health if not properly identified, evaluated, tested and controlled. OSHA has developed a standard for Confined Spaces in Construction (29 CFR 1926 Subpart AA) for any space that meets all of the following criteria: Is large enough for a worker to…...

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OSHA issue Enforcement Policy Memo to Regional Administrators on “RAGAGEP in Process Safety Management Enforcement”

May 11, 2016 MEMORANDUM FOR: REGIONAL ADMINISTRATORS THROUGH: DOROTHY DOUGHERTY, Deputy Assistant Secretary FROM: THOMAS M. GALASSI, Director Directorate of Enforcement Programs SUBJECT: RAGAGEP in Process Safety Management Enforcement   NOTE:  much of the emphasis has been added by me This enforcement policy addresses the Process Safety Management (PSM) Standard’s recognized and generally accepted good engineering practices (RAGAGEP) requirements. Enforcement activity,…...

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OSHA PSM citations @ Ethanol Plant (Flammables & $80K)

On May 6, OSHA issued 42 serious and four other-than serious safety and health violations following three separate inspections at the bio-refinery in November 2015.  Inspectors found the ethanol production facility violated OSHA’s process safety management regulations including failing to: Develop written procedures for safely conducting tasks in the process, and for maintaining the ongoing…...

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90 Cognitive Biases

  Many of these biases affect belief formation, business and economic decisions, and human behavior in general. They arise as a replicable result to a specific condition: when confronted with a specific situation, the deviation from what is normatively expected can be characterized by: Ambiguity effect – the tendency to avoid options for which missing…...

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Combustible Dusts Hazards and OSHA signage

I came across this citation at an Ethanol plant (May 2016) regarding their combustible dusts hazards and the lack of WARNING signs… Citation 2 Item 1 Type of Violation: Other-than-Serious; $0.00 29 CFR 1910.145(c)(2)(i): Caution signs shall be used only to warn against potential hazards or to caution against unsafe practices:… Membership Required You must...

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OSHA PSM citations @ foodservice distributor (NH3 & $72K)

Responding to a complaint from employees at a facility operated by the fourth largest foodservice distributor in the U.S., OSHA found that a check valve in the food plant’s pump room leaked about 9 pounds of anhydrous ammonia on Oct. 21, 2015. Inspectors also found the ammonia sensor in the pump room did not sound…...

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OSHA Clarifies the Flammable Atmospheric Storage Tank PSM Exemption and why they seek to change it

The existing PSM standard applies in part to processes involving a flammable liquid or gas on site in one location in a quantity of 10,000 pounds or more. However, the existing PSM standard contains an exemption for “[f]lammable liquids stored in atmospheric tanks or transferred which are kept below their normal boiling point without benefit…...

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Process Safety Management SER Background Document (May 2016)

As an initial step, and prior to publication of any proposed changes to existing rules or enforcement policies, OSHA is convening a Small Business Advocacy Review Panel (“SBAR Panel”) in accordance with the Regulatory Flexibility Act, or RFA (Sections 601 through 612 of Title 5 of the United States Code). This Panel consists of members from OSHA, the…...

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Process Safety Management Small Business Regulatory Enforcement Fairness Act (SBREFA) SER Background Document (May 2016)

The Process Safety Management (PSM) standard is intended to prevent or minimize the consequences of catastrophic releases of highly hazardous chemicals (HHCs). It requires employers to adopt a comprehensive management program that integrates technologies, procedures, and management practices to help assure safe and healthy workplaces. OSHA is considering revisions to the PSM standard, including changes…...

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UPDATE on OSHA’s PSM Revisions (May 2016)

Last week OSHA shared an update on where they are at with their desired revisions to the PSM standard (1910.119).  Some of the potential PSM Revisions include:   Atmospheric Storage Tanks Oil and Gas-Well Drilling, Servicing, and Production Chemical Reactivity Safer Technology and Alternatives Additions to Appendix A Chemicals Dismantling/Disposal of Explosives Define/Updating RAGAGEP Mechanical…...

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Diesel Fuel Flash Fire?

Back on March 4, 2016 a contractor/truck driver was transferring “diesel fuel” of some type from a storage tank to his truck when there was a flash fire.  He received 2nd and 3rd degree burns over 50% of his body and has since passed away from his injuries.  When I saw this incident in my…...

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