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What an Ammonia Vessel inspection and their RVs should look like

With OSHA’s recent revision of their definition of “retail”, there are literally thousands of ammonia facilities that have entered into the world of PSM and have gone from RMP 2 to RMP 3.  So this posting is just to offer some insight and/or an alternative to API 510 inspection practices and to help those facilities…...

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OSHA says fainting at the sight of blood is RECORDABLE

Scenario: An employee scratched his index finger on a vinyl saw clamp at work. He immediately began walking to the onsite first aid station to obtain a Band-Aid. On the way, the injured employee met a co-worker who told him that he had a Band-Aid in his pocket. As the co-worker began to apply the…...

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OSHA restates Injury/Illness Recordkeeping requirements for temp/contract workers

For many years OSHA has taken the position that the company who “supervises the daily activities” of the worker is the company who has to record their injuries on their 300 Log.  I am guessing that with all the recent emphasis on “temporary workers”, the recordabiity question was asked once again and ONCE AGAIN OSHA…...

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CFATs Program Statistics as of November 2, 2015

More than 50,000 preliminary assessments were reviewed by DHS from facilities with chemicals of interest 3,146 facilities are currently covered by CFATS More than 3,000 facilities voluntarily removed, reduced, or modified their holdings of chemicals of interest   2,111 visits to assist facilities with compliance   3,242 Security Plans authorized     2,658 Authorization Inspections conducted…...

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NSC’s Safety Professional Salary Survey 2015

According to the results of the survey, the average safety professional is a man. More than three-quarters (77.6 percent) of respondents were male, while only 22.4 percent were female.  Another defining feature: age. Nearly two-fifths (17.4 percent) of the respondents are at least 60 years old, and more than half (54.3 percent) are at least…...

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CSB FY 2015 Management Challenges (OIG Report)

Enclosed are the Office of Inspector General’s (OIG’s) three fiscal year 2015 management challenges and one internal control weakness for consideration as part of the U.S. Chemical Safety and Hazard Investigation Board (CSB) Federal Managers’ Financial Integrity Act review. The Reports Consolidation Act of 2000 requires our office to report what we consider the most serious…...

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EPA RMP Citations @ controlled temperature laboratory (NH3 & $85K)

GENERAL ALLEGATIONS Respondent operates a controlled temperature laboratory, where it conducts research on the effect of cold temperatures on equipment, structures and technological systems, at its Cold Regions Research and Engineering Laboratory.  The Facility is located approximately two miles north of the center of Hanover, New Hampshire. The 30-acre site is bordered on the north…...

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MSA User Safety Notice – 50ft./15m. Workman® Self-Retracting Lanyard

MSA is issuing this User Safety Notice due to a potential safety issue involving 50ft./15m. Workman SRLs.  We apologize for any inconvenience that this may cause. We have determined that a small percentage of Workman 50 ft./15 m. SRLs manufactured from January through August of 2015 may have an improper brake nut torque setting.  This…...

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EPA RMP General Duty Citations @ disposal facility (Flammables, Hotwork & $37,500)

Respondent owns and operates a disposal facility associated process equipment.  At the facility the Respondent stored produced water, including residual hydrocarbons, in a 500-barrel fiberglass tank. Produced water stored in this tank was generated from multiple wells. Produced waters, and their associated vapors, are extremely hazardous substances due to their flammability and explosive nature. On…...

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Why Excess Flow Valves FAIL

For several years now, with OSHA and EPA have issued bulletins/alerts regarding Excess Flow Valves.  These alerts/bulletins warned against placing too much faith in these valves when it comes to PREVENTING a “catastrophic release”.  These valves do not have a history of failing because of defects, they have a history of failing due to IMPROPER…...

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