Attached is the written program for General Industry facilities which incorporate OSHA’s newer Confined Spaces in Construction requirements. It is my recommendation that we UPDATE our written program that was based on the older 1910.146 standard to include all the improvements in 1926.1201 – .1213. We should also understand that even though our facility may…...
The Risk Management Program (RMP) regulations require the owner or operator of a stationary source to revise and update the source’s RMP at least once every five years from the date of its initial submission or most recent full update (§68.190(b)). Is there a procedure for obtaining an extension to complete the five-year review? … Membership...
The Risk Management Program emergency response coordination activities require the owner and operator of a stationary source to provide to the local emergency planning and response organizations: the stationary source’s emergency response plan if one exists; emergency action plan; updated emergency contact information; and any other information that local emergency planning and response organizations identify…...
How much time does the owner or operator of a stationary source have to submit a correction to a Risk Management Plan when the emergency contact information changes? The Risk Management Plan (RMP) regulations require an owner or operator of a stationary source to correct their RMP within one month (i.e., 30 days) of any…...
Under most circumstances, where servicing or maintenance is to be conducted during only one shift by a small number of persons, the installation of each individual’s LOTO device on each energy isolation device would not be a burdensome procedure. However, when complex equipment is being serviced or maintained, when there are many sources of energy,…...
The first element is whether strategic plans and action plans integrate safety into all aspects of an organization’s activities. Are there measurable short, medium, and long-term safety objectives in these plans, and is there regular progress monitoring in implementing the plans? Monitoring progress by the senior management team is vital to good safety leadership. Regular…...
Anyone who has played sports or even just attended a team sporting event has heard or seen the famous saying: There is no “I” in Team! In our world of Lockout/Tagout (LOTO), nothing could be farther from the truth! There is not an act in occupational safety and health that is more self-serving and selfish…...
Can cylinders of Anhydrous Ammonia (NH3) be stored with oxygen cylinders? This is not meant to be a trick question, but it is a question I find to be confusing for employees who place cylinders into storage. So what is your answer: Can cylinders of Anhydrous Ammonia (NH3) be stored with oxygen cylinders?… Membership Required...
Respondent operates a seafood processing facility where anhydrous ammonia was present in a process above the 10,000 pounds TQ. Respondent has one program 3 process, an ammonia refrigeration process consisting of a brine chiller system, seven plate freezers, one blast freezer and one ice house with three ice machines. An RMP was submitted for the…...
The following is a list of key safety measures developed by EPA in coordination with the International Institute of Ammonia Refrigeration (IIAR). They are measures that EPA and IIAR agree are required elements for ammonia refrigeration facilities (regardless of an ammonia refrigeration system’s age or size) for the system to meet the requirements of 40…...
First I want to thank my Pittsburg friends for another great visit and for being my “think-tank” of world-class engineers and chemists. I always leave smarter and happier after my time with these folks. And with all my visits I always come away with great real-world examples of how process safety is supposed to be…...
As we discussed last week, the 7th Edition of the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) has quite the change as it relates to flammable gases. We now know there are three (3) Categories of flammable Gases: 1A, 1B, and 2. The 1B is the new one and was in put…...
