NOTE: Another EPA RMP inspection where they took issue with the use of “ribbons” used in lieu of lockout locks! EPA has determined that Respondent violated the Risk Management Program (RMP) regulations promulgated at 40 C.F.R. Part 68 under Section 112(r) of the Clean Air Act (CAA), as noted on the enclosed Risk Management…...
If you stay in process safety long enough you will see some scary stuff! It seems that “piping inspections” are become the norm these days, which after only 27 years of OSHA’s PSM standard being around I guess it is “about damn time!”. Having grown up in the chemical industry, MI inspections were a way…...
This week we saw OSHA issue $300K in citations to a MS papermill, of which LOTO was an area that was cited. One particular situation that caught my eye was the citation regarding “troubleshooting” behind a guard…. (see item (a) below)… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log...
This is one type of situation where (c)(5) could be a means to enter a PRCS and OSHA agreed and issued some (c)(5) citations. At 8:15 p.m. on May 25, 2018, Employee #1 was power washing the outside of the semi-truck tanker trailer. The employee entered the tanker trailer to wash the inside and was…...
At 11:00 a.m. on June 1, 2018, an employee was transferring a chemical degreaser containing 1-5% caustic sodium hydroxide, from a 5-gallon jug into a small bottle. The chemical spilled onto the employee’s left hand and pants. The employee took off his pants, wiped his legs with wet cloths, and changed clothes. However, the employee…...
At 2:30 p.m. on March 10, 2018, Employee #1 was using an aerial lift to gain access to an emergency access panel on a dust collection silo that was 25 feet above the ground. From the aerial lift, Employee #1 was using a two-inch water hose to spray water into the silo to remove the…...
This case is a perfect example of how OSHA will use the newer Construction Confined Space Standard in a general industry workplace based on the actual work being performed. At 3:30 p.m. on May 3, 2017, Employee #1 was spray coating the inside of a 6 foot by 23-foot stainless steel tank, using Plasite 7133,…...
On May 5, 2018, Employee #1 was retrieving a plastic liner bag from a chemical container that had fallen into Reactor CP-2; a confined space. The permitting process, including air monitoring and setting up of ventilation, had not been conducted. As Employee #1 descended a ladder to access the reactor, he passed out at the…...
At 4:00 p.m. on January 5, 2018, Employee #1, employed by an industrial cleaning company, was working at a multiemployer project. He was working from an 8-foot stepladder, Werner Fiberglass 300-pound capacity P/N 100521-127 Model Number T6208 Mk 4. He was 2 feet above the ground and monitoring and adding water as necessary to evaporator…...
Recently I came across a situation at a facility that is NOT all that uncommon and we need to spread the word. It involves using an electrical disconnect on an electrical panel door. As you will see in the STAGED video (NO one was at risk in the video) that I turned the disconnect off,…...
There may come a time that we need to pressure test one of our pressure vessels after a repair or alteration and our FIRST CHOICE of methods to use should be Hydrostatic as it is MUCH SAFER than pneumatic. However, in some cases, we may NOT be able to perform a hydrostatic test for a…...
Some processes have a relief system that includes a rupture disk below the relief valve. This is done for several reasons, but the two most common reasons are: The process is corrosive and can cause issues with the Relief Valve leading to failures and a shortened life span The process contains a Category M fluid and any leakage, ever…...
