OSHA Compliance

Why does the IFC 2024 Flammable Liquids Chapter (57) reference ASME B31.9 for leak testing rather than B31.3?

NOTE: If you’re in an INDUSTRIAL facility, especially one with a PSM/RMP-covered process, B31.9 is NOT your piping RAGAGEP! IFC 5703.6.3 dictates that piping for flammable and combustible liquids must be hydrostatically tested to 150% of the maximum anticipated pressure (or pneumatically tested to 110%). However, it offers a carve-out: “Unless tested in accordance with…...

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Can anyone perform the “annual maintenance” on fire extinguishers?

I get some interesting questions and see some very strange things in my work around the country, but this one seems to have grown legs in the world of “cost-cutting” in safety. “Let’s have our maintenance people do the ‘annual maintenance’ on our fire extinguishers”… um NO WAY! And this is just not a “Haywood…...

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ASME and PSM/RMP conflict on “records retention” needs

I will be fully upfront for those who wish to challenge me on this topic. YES, ASME B31.3 and 31.5 explicitly state that certain records that are required by the standard do NOT have to be “retained”. However, most people who challenge me on this topic fail to see that ittybitty two-letter word “if” in…...

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Refinery fined £1 million after major gas leak

Structural collapse caused the release of around 2,400kg of highly flammable liquid petroleum gas.HSE investigation found that long-standing corrosion of the steel tower was not dealt with.Workers exposed to the risk of serious injury and burns in a major incident. The refinery has been fined £1 million after a major gas leak following an investigation…...

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OSHA’s ability to use the GDC at facilities that fall under the PSM TQ

OSHA uses the General Duty Clause (GDC), Section 5(a)(1) of the OSH Act as a “gap filler” to cite employers for recognized chemical hazards when a specific standard (like the Process Safety Management standard, 29 CFR 1910.119) does not technically apply. There are some critical legal limitations on GDC Enforcement: OSHA’s ability to invoke 5(a)(1)…...

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NH3 Refrigeration GDC citation

Not having an ammonia detection system, which had been cited the previous year, also as a GDC; however, it seems the business was sold, and the new owner was cited for not addressing the detection system…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Another PSM GDC citation in NH3 Refrigeration

As I said in my previous posts on GDC PSM citations, this is new territory for me and OSHA enforcement. I was always taught (and by some very sr. OSHA personnel) that OSHA can not use the GDC to enforce hazards for which OSHA already has a standard for. It was OSHA’s “carrot and stick”…...

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Can OSHA issue 5(a)(1) citations when a process is under its PSM TQ?

Apparently, they can and have. Here are some GDC citations for an NH3 refrigeration process. These were part of a large release inspection that included some HAZWOPER and HAZCOM citations. My only guess is that these GDC citations are tied directly to the NH3 release, but I have not yet seen the field notes, so…...

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NFPA updates its 704, Standard System for the Identification of the Hazards of Materials for Emergency Response

The 2027 edition of the standard includes new definitions for the terms battery energy storage system and lithium-based battery with associated annex material. Updates have been made in Section 6.2 to align with NFPA 1 regarding 1A and 1B flammable gases and to further clarify that Category 1B has a lower flammability than Category 1A…...

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What is OSHA proposing to change in the respiratory protection program?

OSHA is proposing several updates to its Respiratory Protection Standard (29 CFR 1910.134) as part of a broader deregulatory effort to reduce employer compliance costs and provide greater flexibility, without compromising worker safety. Here are the key changes currently on the table:… Membership Required You must be a member to access this content.View Membership LevelsAlready...

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3 executives receive 2-years in prison for the death of a worker in a 2019 fire; two of those being prosecuted were “risk prevention technicians”

SAFTENG NOTE 1: Two (2) of those being prosecuted were risk prevention technicians; one was a company employee, and one was a contractor SAFTENG NOTE 2: This silo explosion is very similar to the recent silo explosion in ME that took the life of a Firefighter Three (3) executives from an industrial wood processing and…...

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Is a Tanker Truck a “shipped container” under OSHA’s GHS/HAZCOM?

If we look closely at this ISO container, specifically between the two (2) placards, we will see a laminated GHS label with the product identifier, pictogram(s), signal word, manufacturer’s name, and phone number. But is that middle label required on this ISO container?… Membership Required You must be a member to access this content.View Membership...

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