UPDATED on 2/6/19, based on feedback from my friend and Refrigeration PSM Extrodinare Brian Chapin over at RCE (A former Partner in Safety). I have shared his analysis and my rebuttal/agreement… By a long shot, these are the top three (3) issues found with Ammonia Refrigeration RMPs: The NH3 is “Liquified by Pressure” – not […]
This 10-minute video provides an overview of the OSHA inspection process under the agency’s Regional Emphasis Program for Fertilizer Grade Ammonium Nitrate and Agricultural Ammonia Facilities.
One of my favorite parts of teaching the 1-day PSM Intro course at ASSE SeminarFest is the vast numbers of students and all of their learnings and experiences being shared. This year was even better than years before – in fact, we had so many side-bar discussions because of the great input from the students
Those in the PSM/RMP world know that the facility is REQUIRED to have an Emergency Action Plan (1910.38) and by virtue of having to comply with 1910.38, we also have to comply with 1910.165 Employee Alarm System. The language in 1910.165 is really vague and causes much confusion when it comes to the emergency alarm
Breathing… we do it all day long, every day, and yet we never even put a thought to it. But so many respirator users do not understand the basics of how we get the air (more importantly, the oxygen in the air) into our lungs so that it can enter our bloodstream for survival. As
Recently I had a client who made alterations to a pressure vessel (PV) in an ammonia refrigeration process that required the PV to be re-certified. The state where this PV resides is a “coded state”, meaning they have adopted ASME Code for the PVs within the state. So, the contractor making the alterations had scheduled
If API 570 is your facility’s piping inspection/repair RAGAGEP, the battle over “repair requirements” just got easier! A very popular question in PSM/RMP circles has become… “Do we have to make repairs in the same manner as we did the initial install of the pipe?” In other words, what is being asked is… “Can we bypass
In my travels to our friends north of the US border, it is not uncommon to find “used vessels” in service that were never intended to be used that far north and for the record, this occurs in the USA northern states as well. The figure below is one that is used by many to
Scenario 1: The first scenario you described has the following attributes: Your firm is engaged in the design and construction of a manufacturing (processing) facility which includes OSHA Category 2, 3, and 4 flammable liquids as raw materials and processing intermediates. The Food and Drug Administration and countries in Europe, the Middle East, and Africa
Another aspect of a “respiratory protection program” often times will include a PFT as part of the “medical evaluation”. For the most part, these PFTs are done by the location where the PLHP resides and most of the time they are done by “trained” personnel – but how many of us actually audit the service provider
I have received a number of e-mails, text, and phone calls concerning OSHA’s change in their Electronic Filing of Injury and Illness data. Bottom Line… 300A Annual Summary Data is all that is required to be submitted for those establishments that have 250 or more employees. TIP: “employees” are that personnel on site that if they
Fire Codes mean something… at least in our world of occupational safety and health. As I was entering a restaurant for dinner, I am checking out my environment and what do I see but two (2) dewars of Nitrogen in some kind of “float spa”. This was in a “strip mall” type setting so of course,
