Safety Info Posts

Understanding why we have 1910.165(b)(3) (all pun intended)

1910.165(b)(3) The employee alarm shall be distinctive and recognizable as a signal to evacuate the work area or to perform actions designated under the emergency action plan.   After an employee becomes aware of an emergency situation, the next step involves actions to be performed by that employee. Generally, the actions include evacuation or emergency […]

What to do when my RAGAGEPs conflict (CGA 2.1, 5.6.10 vs. B31.3, 345.5)

As we continue to “dumb down” RAGAGEPs to take away OSHA/EPA’s ability to cite fundamental engineering failures found in processes handling HHC/EHS, the issue of “conflicting requirements” continues to be troubling.  As my Anhydrous Ammonia clients learned firsthand last year, with the 7th edition of CGA 2.1, the RAGAGEP has some NEW requirements for pressure

New HAZMAT exemptions (2024 IFC)

The 2024 edition of the International Fire Code has a new “table” that lists several exemptions.  These exemptions come with some limitations, such as… Exempted materials and conditions listed in this table are required to comply with provisions of this code that are not based on exceeding maximum allowable quantities inSection 5003. Here are a

Responding to “small releases”

Both OSHA and EPA require PSM/RMP facilities to include procedures for “responding to small releases” in their Emergency Action Plans 1910.119(n) Emergency planning and response The employer shall establish and implement an emergency action plan for the entire plant in accordance with the provisions of 29 CFR 1910.38. In addition, the emergency action plan shall

Understanding our LOPC Flammable and Toxic Risks

A loss of containment and subsequent release of fluids can cause adverse consequences (i.e., impact safety, health, and environment, cause production losses, andincur maintenance and reconstruction costs). The risk analysis should consider the nature of the hazards and ensure that appropriate factors are considered for the equipment items being assessed. Flammable Events (Fire and Explosion)

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