Safety Info Posts

OSHA PSM Process Hazard Analysis Citations in 2022

In OSHA’s fiscal year 2022, Process Hazard Analysis was the #4 most cited element of the PSM standard. Here is a breakdown of those citations…… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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OSHA PSM Process Safety Information Citations in 2022

In OSHA’s fiscal year 2022, Process Safety Information, was the #3 most cited element of the PSM standard. Here is a breakdown of those citations…… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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OSHA PSM Mechanical Integrity Citations in 2022

In OSHA’s fiscal year 2022, Mechanical Integrity (MI), was the #2 most cited element of the PSM standard.  Here is a breakdown of those citations…… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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SOPs over take MI in OSHA’s 2022 PSM citations

OSHA’s fiscal year 2022 saw a significant change in the leading PSM element for citations.  As far as I know, Mechanical Integrity has been the most cited element every year for the past 20 years.  And it held that spot convincingly for those years.  Last year, SOPs took the top spot with…… Membership Required You...

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Detailed breakdown of PSM inspection data for 2022

In my earlier post, my data showed OSHA conducted 66 PSM inspections and issued 347 citations.  Now that I have all the data in raw form, I saw 430 citations in 2022.  The discrepancy is likely due to one database using the “issuance date” and the other using the “final order” date.    And yes,…...

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Safe Work Practices, Operating Procedures and Maintenance Procedures are a STARTING POINT!

Maybe I’m just old school, but is it just too much to ask for: a well written safety procedure, one that is written and analyzed with a safety pro and the worker(s) who do the actual work, that management will fully support the procedures everyday-everytime, including on holidays that fall on a Sunday, and employees…...

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EPA RMP GDC @ ice rink facility (NH3 & $6K w/ Plan)

Respondent operates an ice rink facility with an ammonia refrigeration system. The System uses or used anhydrous ammonia, a chemical that is listed pursuant to Section 112(r)(3) as an “extremely hazardous substance” and that is subject to the General Duty Clause. In March of 2022, Respondent’s response to an Information Request issued by EPA revealed…...

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EPA RMP Citations @ animal slaughtering facility (NH3 & Compliance Plan)

Respondent is the owner and/or operator of an animal slaughtering facility where anhydrous ammonia is used in refrigeration systems. The Respondent conducted an offsite consequence analysis in early 2022, showing that the population inside the worst-case scenario radius includes 961 houses, and 2,851 people could be exposed to this release. The Respondent also conducted an…...

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EPA RMP Citations @ ingredients facility (EO and N(CH₃)₃ & Compliance Plan)

Respondent is the owner or operator of an ingredients facility with greater than 10,000 pounds of ethylene oxide in a covered process and greater than 10,000 pounds of trimethylamine in a covered process at the Facility. From the time Respondent first had onsite greater than 10,000 pounds of ethylene oxide and/or trimethylamine in a process,…...

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EPA RMP Citations @ chemical distribution facility (Formaldehyde & $125K)

The Respondent owns or operates a chemical distribution facility where the respondent has used or stored more than 15,000 pounds of formaldehyde. 40 C.F.R. § 68.25(a)(2)(i) requires the owner or operator of a stationary source to analyze and report in a Risk Management Plan (“RMP”) the worse-case release scenario that is estimated to create the…...

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PRCS Fatality (HAZ ATM); 1 entrant and 1 would be rescuer

On June 7, 2022, an employee working as an environmental engineer was replacing two failed pumps in a pump station. Two coworkers connected the new pumps to electricity, and the employee lowered the pumps into the vault. It was noted that the pumps weren’t working correctly, and water was pumped from the space. The employee…...

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