Moving from PSM/RMP Operating Procedures to Emergency Action Plan (EAP) to Emergency Response Plan (ERP)
I have discussed this many many times with clients over the years, as most have difficulty seeing the logical transition from each phase to the higher level of response. So in this article, I will attempt to show the transition as to when we leave PSM/RMP operating procedures to our EAP and if necessary how
EPA RMP citations @ chemical facility (VA & $14K)
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 Plan Inspection Findings and Alleged Violations Summary (“Summary”), which is hereby incorporated by reference. In consideration of the penalty assessment factors
2018 Video of the Week #44 (When things go wrong, your training matters!)
This year I have shared several videos of flammable liquid transfers that were done badly with serious consequences. To end the year on a positive note, this week’s video is one showing things going wrong and then the TRAINED WORKER steps in and uses his training to end the incident as well as could have
OSHA PRCS citations @ tanker cleaning company
OSHA has cited a tank cleaning company $171,281 in penalties for confined space, fire, and explosion hazards. OSHA inspectors determined that the company allowed employees to enter a tank without testing for atmospheric hazards. The company was cited for allowing employees to use a non-explosion proof vacuum in a tank that transported a highly hazardous
Contractor in a Chlorine Process – HAZCOM or PSM training and Fit-Testing needs? (OSHC)
This case involved a contractor working in a Chlor-Alkali Unit when there was a Cl2 leak. Six of the contractors had to go to the hospital due to exposure to Cl2 due to their inability to evacuate up-wind. There was a lot of factors in this case, but OSHA issued two citations: HAZCOM – as
Venting Requirements for “Inside Flammable Liquid Atmospheric Aboveground Storage Tanks (AST)”
A fairly common debate I have with folks is the “normal venting” and “emergency venting” requirements for “Inside Flammable Liquid Storage Tanks.” The bottom line…These tanks MUST be vented outside the building for normal and emergency venting, except for Class IIIB liquids. Tanks Inside Buildings (TINBIDS) requirements in Chapter 57 of the IFC become applicable
Fernie Investigation- Findings & Recommendations for Refrigeration Contractors/Mechanics (Video Presentation)
This is a recording of a live session that took place on October 30, 2018. The session was intended for refrigeration contractors & mechanics. The following was covered: Key findings of the Fernie Investigation Recommendations from the Investigation that pertain to owners/operators of ammonia refrigeration plants Open question & answer period
Fernie Investigation- Findings & Recommendations for Refrigeration Contractors/Mechanics (Video Presentation)
This is a recording of a live session that took place on October 30, 2018. The session was intended for refrigeration contractors & mechanics. The following was covered: Key findings of the Fernie Investigation Recommendations from the Investigation that pertain to owners/operators of ammonia refrigeration plants Open question & answer period
OSHA submits RFI regarding computer-based controls of hazardous energy vs. traditional LOTO
Recent technological advancements that employ computer-based controls of hazardous energy (e.g., mechanical, electrical, pneumatic, chemical, and radiation) conflict with OSHA’s existing lock-out/tag-out standard. These computer-based controls have become more prevalent as equipment manufacturers modernize their designs. Additionally, national consensus standards and international standards harmonization govern the design and use of computer-based controls. This approach of
OSHA LOI on the GHS HAZCOM standard
MSDSonline has shared their LOI from OSHA regarding 16 well-crafted questions they submitted to OSHA regarding the GHS HAZCOM standard. Some of OSHA’s answers may be a wake-up call for some businesses who “import” chemicals and most will be surprised by who is an “importer” in the eyes of OSHA.