This is a topic that is near and dear to me, as it is one I learned very early on in my career as a means to safely perform PRD work on an RV or RD that is connected to a header/manifold. Although this design MUST be adequately done AND must be managed very tightly,…...
OSHA has cited a Chemical Manufacturer after an employee died due to lack of oxygen while cleaning the inside of a railcar. A second employee who tried to rescue the co-worker was also overcome but survived. OSHA has proposed $64,857 in penalties. The facility was cited for failing to provide respiratory protection; properly ventilate a confined…...
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This is a great example of “know your surroundings”! LNG is INVISIBLE, even on the most humid of days, when its at its LEL – meaning, although there is no “cloud” there is a good chance you may be in a flammable atmosphere if your around an accident. These people had no way of knowing…...
Respondent is the owner or operator of an egg production facility which employs a refrigeration process using anhydrous ammonia in its egg production system. Pursuant to Section 112(r)(1) of the CAA, also known as the General Duty Clause, the owners and operators of stationary sources producing, processing, handling or storing substances listed pursuant to Section…...
This case is being posted, even though the citation was under $10,000 because it is a GDC case and involved improper storage of materials that would react to create an extremely hazardous substance. EPA used both NFPA 30, 2015 and the IFC, 2015; as well as NFPA 704 in their assessment. The respondent has owned…...
This is a classic. Details matter, contrary to what many want to claim about safety plans, programs, practices, and operating and maintenance procedures. The fact is, there MUST be a balance between details and length and complexity. Some jobs will need a 10-page procedure, and some will need a half-page. The idea that shorter is…...
Over the years, I have encountered some great learning opportunities, many occurring during my VPP assessments. In one such evaluation in Alabama, the CSHO pointed out that our PRCS Labels were on the actual coverings over the entry portals (e.g., manways). As he explained, in that set-up, OSHA would not require the space to be…...
In OSHA’s 2018 Permit-Required Confined Spaces; Extension of the Office of Management and Budget’s (OMB) Approval of Information Collection (Paperwork) Requirements, they noted some fascinating numbers as they relate to PRCS’s in the USA… number of establishments with permit spaces = 210,281number of entrants entering these spaces = 1,471,634… Membership Required You must be a...
Respondent owned and operated a Natural Gas Processing facility, which produces, processes, stores, or handles more than 10,000 pounds of a flammable mixture, including pentane, isobutate, isopentane, butane, propane, and ethane in the form of natural gas, natmal gas liquids, condensate, and/or crude oil. Pentane, isobutate, isopentane, butane, propane, and ethane are identified at 40…...
The CSB faces two management challenges that, if not addressed, may seriously impede the agency’s ability to achieve its mission efficiently and effectively. Based on our continuous audit work, the EPA OIG has identified two management challenges for the CSB that were not in the fiscal year 2017 report: the lack of authority that…...
UPDATED 2/16/2021 with OSHA Case File A couple of KEY POINTS in this EMA’s report out to the County Supervisors: Two weeks before this incident the County had conducted a drill at another NH3 facility that involved a rooftop NH3 leak (PREPAREDNESS) The release came from a 14″ diameter suction line on the roof of…...
