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OSHA PSM citations @ warehousing and logistics facility (NH3 & $58K)

OSHA initiated the October 2015 inspection following a report of an ammonia release (apparently during a manual purge of NH3) at the warehousing and logistics company. The agency cited the company for nine serious violations, six for process safety management standards violations, two for not fit testing or providing a medical evaluation of employees before…...

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NFPA 59A and Car-Seal Program

As the debate rages on whether an intervening valve can be placed between a relief valve and the vessel it is protecting, I offer up NFPA 59A as another source for the answer YES.  In fact, NFPA 59A (2016) requires either a stop valve or RV tree so that the RV’s can be changed without…...

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Pipe flanges, screwed connections, fittings, valves, meters, etc. and our Hazardous Locations

When establishing our Hazardous Locations (HAZLOC) we utilize a Recognized And Generally Accepted Good Engineering Practice (RAGAGEP) such as NFPA 497, Recommended Practice for the Classification of Flammable Liquids, Gases, or Vapors and of Hazardous (Classified) Locations for Electrical Installations in Chemical Process Areas or there is also API RP500, Recommended Practice for Classification of Locations…...

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2016 Video of the Week #12 (NEVER stand on the top of a step ladder)

WARNING!  Viewer Discretion Advised.  Video shows worker falling off 8′ step ladder and landing hard.  Worker was severely injured.  … Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Inside look at OSHA’s desired PSM revisions

Potential PSM scope items: Clarifying the exemption for atmospheric storage tanks Removing the exemption for Oil- and Gas-Well Drilling and Servicing Resuming Enforcement for Oil and Gas Production Facilities Covering reactive chemical hazards Updating and expanding the list of HHCs in Appendix A of the existing PSM standard Covering dismantling and disposal of explosives and…...

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Use of Aftermarket Replacement Component Parts for NIOSH-Approved Respirators (NIOSH)

Worker safety can be compromised by using replacement component parts or accessories that are not NIOSH-approved for the specific respirator. Although NIOSH-approved respirators are comprised of various component parts, they are approved as a complete unit. The use of components which are not part of the approved assembly results in a respirator that has not…...

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Revised Interim Enforcement Procedures for Reporting Requirements under 29 C.F.R. 1904.39

This memorandum provides updated internal guidance and procedures for the Area Offices to enforce the reporting requirements. Among other things, this memo updates the procedures for the intake of reports from employers, data collection and sorting; and entry of data in the OIS system.  Revised flow charts are provided to help understand the intake process…....

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Year One of OSHA’s Severe Injury Reporting Program: An Impact Evaluation (OSHA)

Under a requirement that took effect Jan. 1, 2015, employers must report to OSHA within 24 hours any work-related amputation, in-patient hospitalization, or loss of eye. (The requirement to report a fatality within 8 hours was unchanged.) Injuries may be reported directly to an OSHA field office, to the OSHA toll-free number, or via an online…...

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EPA RMP GDC citations @ chemical plant (Polyvinyl Chloride (PVC) & $33K)

This investigation began after a 9.6 pound vinyl chloride release from an improperly installed rupture disc (RD). The rupture disk had been improperly installed per original design, and its identification tag had been improperly inserted in the rupture disc holder.  Just last night I posted an incident where a “low pressure” vessel catastrophically failed because it did…...

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EPA RMP citations @ food plant (NH3 & LPG, $52K)

This is an interesting CAFO!  The facility has a 30,000 gallon LPG tank which they use the fuel for heating water to produce steam to cook its product.  The LPG is exempted from Part 68 since it is “used as a fuel”; HOWEVER, EPA pulled out their “General Duty Clause” and cited the facility for the…...

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Cost–Benefit Analysis of Proposed California Oil and Gas Refinery Regulations (RAND Corp)

The research reported here assessed the costs and benefits of the proposed California process safety management (PSM) and California Accidental Release Prevention regulations that are designed to improve safety at oil and gas refineries in California. The authors estimate these costs and benefits in four categories: costs to industry (to implement the regulation), costs to…...

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