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Breaking down OSHA’s General Hotwork Requirements (1910.252(a)

For those of you at PSM/RMP covered facilities, this OSHA standard is a baseline requirement; however, this OSHA standard does NOT require a Hotwork permit.  It merely “prefers” the authorization be “in the form of a written permit”.  It was not until OSHA’s Process Safety Standard (and EPA’s RMP) that OSHA/EPA actually REQUIRE a hotwork…...

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OSHA PRCS citations @ Railcar Cleaning business (Flammable Atmosphere & $963,000)

Moments before a blast ripped through a railcar on April 14, 2015, a check of the air quality inside indicated a serious risk of an explosion. Despite the warning, the company sent two employees, aged 41 and 45, into the railcar to work without monitoring the air continuously for explosive hazards as required, nor providing…...

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Atmospheric Storage Tank fails under fire conditions (caught on helmet cam)

This was an atmospheric storage tank containing diesel fuel that failed under fire conditions.  I believe this to be merely a failure of an atmospheric storage tank under fire conditions and the sounds from the video make it appear that the vent was either obstructed or an undersized vent OR the venting we hear just…...

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The five (5) KEY differences between PRCSs in GI and Construction and the added provisions that CLARIFY 1910.146 requirements (OSHA)

There are five key differences from the construction rule and several areas where OSHA has clarified existing requirements. The five new requirements include:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Think you have control of your contractors? We may need to think again…

There’s a reason why both OSHA and EPA have requirements to CONTROL the entry of contractors into our covered process(s), their presence, and their exit from the process.  It is so IMPORTANT, we find two (2) places in the standards that require this kind of CONTROL over contractors who wish to work ON, IN, or…...

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Material and Energy Balance and “change to facilities that affect a covered process”

One of the most popular PSM requests I get is for an example of a “change to facilities that affect a covered process”.  In this article, I hope to provide an actual example and how a “change to facilities” can affect an ammonia refrigeration facility.  OSHA’s PSM standard states the following about managing changes… (l)…...

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72 incidents & 1 update (10/11/15)

      Over 12,500 exclusive unsafe acts/conditions and accident/injuries photos and over 1,300 ppt’s & doc’s from more than 2,797 contributors! 2015 Fatality Tracker Electrical 35 (2014 =55) (2013 = 32) (2012 = 68) Forklift/Aerial 46 (2014 = 60) (2013=62) (2012 = 52) Mining* 21 (2014 = 401) (2013=87*) (2012 = 92*) *ONLY developed…...

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2015 Video of the Week #41 (Power of a SCBA Cylinder)

This is an old steel 2216 psi cylinder!  Today’s fiber wrapped cylinders are HIGHER PRESSURE and weigh less so the response would be more than seen in this video.  SCBA Inspections and Hydro static Testing are KEY to ensuring a SAFE CYLINDER…. Membership Required You must be a member to access this content.View Membership LevelsAlready...

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Does ammonia need to be removed from evaporative condenser coils for entry into these PRCSs??

7/7/2020 UPDATE: Found the OSHA Case where an evaporator fan motor bracket failed, causing the fan to fall onto the coil(s) and cause a NH3 release 6/30/2020 UPDATE:  See my video of an NH3 Condenser Tube/Coil failure (Hydraulic Expansion) on my YouTube Channel   In 2012 I attempted to convince you that ammonia evaporative condensers…...

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What it looks like to go from a Level 2 RMP to a Level 3 RMP

The recent change in OSHA’s PSM definition of a “retail facility” is having a large ripple effect all the way across EPA’s RMP rule.  As I wrote about in “How does OSHA’s revised PSM “retail exemption” policy impact my RMP?” this change, thought by many as minor – thus the six-month compliance window for these…...

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