I have been working with a client on developing their PRCS Rescue team and of course, we get to the final phase, training the team, and the questions begin with how long is the training. Now, the topic of training and its time commitment was discussed a long time ago; even before they decided they…...
Incorporated by Reference (IBR) is the act of including a second document within another document by only mentioning the second document. This act, if properly done, makes the entire second document a part of the main document. Incorporation by reference is found over 1,445 times in OSHA standards, with 949 being related to the General…...
The following policy updates apply to anhydrous ammonia storage tanks (tanks) in the state of Kansas as of 2/13/2021. The state has issued new retirement dates for the “railcars” that have been modified and used as fixed storage tanks for decades. This policy is intended to apply to the Fertilizer Industry within the state. It…...
GAO’s analysis of Occupational Safety and Health Administration (OSHA) data showed that the number of recordkeeping violations OSHA cited fluctuated over 15 years. An April 2012 federal court decision (that effectively limited the time period for citing these violations) and a January 2015 expansion of OSHA’s rule for reporting severe injuries and illnesses coincided with…...
Having spent my entire safety career in chemicals, I have always been amazed when communities rezone and permit housing developments such as apartments/condos with high density populations within spitting distance of chemical/processing facilities and then the city officials are furious when there is an event that causes disruption in these housing developments. This story is…...
Years ago, WorkSafe British Columbia (BC) put out a really nice video about a fatality caused by a worker welding on a used Acetone Drum. Although the video states the drum is a 44-gallon drum, it is in fact a 55-gallon drum. 44 imperial gallons is equal to 52 US gallons – which we call…...
The Year 2020 was a trying time, but some exciting news has come out of 2020… Jack Rabbit III is in the works. The Cybersecurity & Infrastructure Security Agency (CSIA) and the Department of Homeland Security (DHS) have been working on the infamous Jack Rabbit study Phase III since early 2020. Without question, these Jack…...
Respondent is the owner and/or operator of the Facility and has developed an RMProgram accidental release prevention program for the Facility. On July 23, 2019 – July 25, 2019, the EPA conducted an on-site inspection of the RMProgram related records and equipment for the purpose of assessing the Respondent’s compliance with the RMProgram requirements and…...
The major hazard involved with transferring flammable liquids is static build-up due to charge separation with the potential for discharge resulting in fire and subsequent loss of containment. Certain non-polar liquids can be charged while flowing through piping. Detectable and hazardous charges must be expected if the specific resistance of the liquid exceeds 108 ohms…....
One of the most hazardous tasks that take place within a chemical process is the NON-Routine Opening of the process. And sadly, there are no RAGAGEPs or OSHA standards that establish minimum safeguards for such hazardous activities. Which I guess in some ways, is better as it has allowed the industry to establish some really…...
As we have discussed before, several years ago a governor of the great state of Washington passed a bill that required all the state’s codes and standards to be written in “everyday language” and oh how I love this approach. Even career safety professionals can struggle to try to decipher what Federal OSHA is really…...
If you’re at a facility where the PSM-covered process involves ammonia refrigeration, OSHA has a few specific questions that would like to ask! These questions are specific to ammonia refrigeration facilities and will be used to evaluate a facility’s readiness to join the world-class ranks of VPP STAR workplaces. How would you fare with these…...
