P1 P2 P3 Third-party audits (applies to the next scheduled audit after an accident) √ √ Incident Root Cause Analysis (only for facilities with accidents/near misses) √ √ Safer Technologies Alternatives Analysis (STAA) (applies to a subset of P3’s in certain NAICS codes) √ Coordinating Emergency Response Program Requirements with…...
I have an on going debate with a new food client on their “spiral freezers” being a Permit-Required Confined Space(s). In my professional opinion, a spiral freezer, at least all the ones I have been around, are without a doubt a PRCS. This company, including their brand manufacturer, are claiming they are not – based…...
I have written about the differences between a CS vs. PRCS many times, but one situation that we must NEVER loose sight of is that many PRCS today are caused by the work taking place within them and NOT the normal PRCS hazards. What do I mean by this? The entry supervisor checks the atmosphere…...
JZ and I got our ASSP Safety2019! reviews today, as well as the recorded sessions were made available last night. Some of those who sent me a not so nicely worded e-mail after the conference have since relistened to the session and a couple of them actually apologized. Although not all have decided I am…...
One of the weakness of OSHA’s PRCS standard(s) (1910.146 and 1926.1200) is that when the space is evaluated and it is determined to only be a Confined Space (CS). Too often we let down our guard and assumed the space will pose no hazards to the workers entering the space. Recently I was made aware…...
One of the more common misses by a lot of businesses, especially those using pressure vessels (PVs) in their PSM/RMP covered processes, is the “initial inspection” at the time of installation. We have discussed the “change of service” inspection several times; however, this inspection is for NEW PVs being installed. This requirement will certainly apply…...
Reminds me of the HFO-1234yf campaign with the “mildly flammable” from the new classification in ASHRAE 34. This one though goes a step further… LPG cylinders are not dangerous, their filled with safety…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
One of the PSM/RMP safe work practices I try and get anyone who I cross paths with to implement on ALL of their hazardous materials (regardless of PSM/RMP applicability) is the Line Break and Equipment Opening procedure and permit process. Too often I learn of incidents in processes where the HHC/EHS was under the PSM/RMP…...
EPA recently announced its enforcement and compliance assurance priorities for fiscal years 2020 to 2023. There are seven (7) priority areas in total for this period, six of which are National Compliance Initiatives (NCIs), which will be led by EPA’s Office of Enforcement and Compliance Assurance. The one that I follow closely is…… Membership Required...
Many facilities have been struggling with their in-house labeling to meet OSHA’s Global Harmonized Standard (GHS) labeling. I have written on this topic too many times to mention since 2015, but one thing that I am finding and I can not explain is how compressed gas manufacturers have not revised their “shipped container” labels to…...
Using “bailing wire” to hold open your deadman valves on oil-pots is a really bad idea… leaving the bailing-wire (e.g. evidence) on the valve after each use is just stupid and shows an auditor/inspector that this is an accepted and continual practice! Another tell-tale indication of cheating a deadman valve is the indentions left in…...
