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EPA releases Q&A’s on Proposed Changes to the RMP Rule

Questions include… Why is EPA proposing amendments to the RMP rule? How is EPA’s proposal related to efforts to implement EO 13650? What are the impacts from accidents at RMP facilities? What requirements are included in the proposal? Has EPA discussed these proposed changes with stakeholders or other federal agencies? How will EPA engage stakeholders…...

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Free PSM Workshop on April 29, 2016 (WA-OSHA, officially called Department of Labor and Industries )

Friday, April 29, 2016; 8:30 a.m. to 3 p.m.  Location: 12806 Gateway Dr. S, Tukwila, WA 98168 If you plan on attending in person please RSVP to [email protected]. Seating is limited. Teleconference number available for this event: 1-866-715-6499 Passcode: 1897720443 Workshop Facilitator: Jerry L. Jones, PE, CSP, CHMM, CFEI, Chemical Engineering Consultant Sponsored by: Washington State Department of…...

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OSHA PRCS citations @ Concrete Plant ($140,000)

OSHA conducted a sweeping inspection of a company that employs about 300 workers at an array of businesses, including a dairy and creamery, farm, concrete plant, auto repair, welding shop, restaurants and lodging, a telecommunications company, graphic design firm and a convenience store.  This company has had three (3) fatalities since 2012 within their businesses and…...

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What is the REQUIRED FREQUENCY of my relief valve(s) maintenance

In my last several Process Safety courses, I had several requests for “code requirements” surrounding Relief Valve “maintenance” (e.g., inspection, replacement, and rebuild frequencies).  In general, there is the “at least every five years” interval that is ever so popular, and the vast majority of manufacturers will REQUIRE their RV(s) the be changed/rebuilt/certified “at least”…...

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OSHA citations for NOT managing Relief Valves on Air Receivers (1910.169)

Here is another recent citation from OSHA on a standard that gets very little attention, 1910.169 Air ReceiversAir Receivers. 1910.169(b)(3)(iv) All safety valves shall be tested frequently and at regular intervals to determine whether they are in good operating condition.                                   Least…...

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OSHA uses 1910.132(c) to cite GI workplace for improper use of PFAS

A question that seems to be asked more and more is “do my harnesses and lanyards fall under the same requirements as those used on construction sites?”.  This is another one of the questions that I have no idea where it came from or how the myth that the Personal Fall Arrest System (PFAS) used…...

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Updating your Asbestos Signs before June 1, 2016 to comply with the new GHS HAZCOM (OSHA LOI)

In 2012, OSHA revised the standard, 29 CFR 1910.1200, Hazard Communication (HCS 2012). [Reference, 77 Fed. Reg. 17574 (Mar. 26, 2012)]. This rulemaking also made minor changes to several other OSHA standards related to hazardous chemical communication, such as revising the legend used on the warning sign to a regulated work area specified in OSHA’s…...

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Tying your Maximum Intended Inventory back to your material and energy balances

In October 2015 I wrote about justifying our Maximum Intended Inventories (MII) so that we balance business needs with risks associated with large quantities of highly hazardous chemicals on site. Now we have come full circle and now a facility is being asked to define their MII as it relates to their material and energy…...

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