Over the years I have facilitated and participated in hundreds of PHAs from toxics to flammables and even some explosives (although not my thing!). And in doing so, one thing that drives me crazy is the lack of structure in how process deviations are identified and studied/analyzed. I love the HAZOP methodology and hate the…...
This is a common question we get when we are working at facilities where there is a mechanical refrigeration system… Do my refrigeration technicians have to be “qualified electrical workers”? Because that question is so broad, we always answer “Yes”, based on our experience around these types of processes, but it depends and here are…...
In the EPA Office of Inspector General’s Semiannual Report to Congress: Oct 1, 2017 – March 31, 2018 we see two “recommendations” regarding the manner in which EPA conducts their Risk Management Plan (RMP) audits and how the OIG feels the process could be improved upon. These are a continuation of improvement from the 2013…...
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With this week’s flash fire that sent over 20 workers to the hospital, I thought this video would be timely. This is a demo video by an FRC maker, and it shows us how the vapor and flame interact. … Membership Required You must be a member to access this content.View Membership LevelsAlready a...
For some reason, we have seen a spike in questions and request to assess the applicability of PSM/RMP covered process(s), and this is beyond the typical “can use the Meer decision to get our flammable process out of PSM?” questions. So I thought it would be helpful to publish OSHA’s official interpretation and explanation of…...
Respondent owns and operates a food service distribution facility that handles approximately 12,000 pounds of anhydrous ammonia at the Facility. EPA conducted an inspection of the Facility on October 18, 2017 (“Inspection”) to determine Respondent’s compliance with CAA Section 112(r)(7) and the Chemical Accident Prevention Provisions at 40 C.F.R. Part 68. Respondent submitted an initial…...
This week I have been working with a new member who has become frustrated with all the different directions and “interpretations” regarding OSHA’s and EPA’s Maximum Intended Inventory requirements. This is my e-mail response – names and titles have been changed to protect the innocent! (LOL) I feel your pain, this one small topic has…...
In FY 2017, OSHA conducted 32,408 inspections, including 18,031 (about 56 percent) unprogrammed inspections, which includes employee complaints, injuries/fatalities, and referrals. The high percentage of unprogrammed inspections indicates that OSHA continues to devote considerable resources responding to referrals and complaints. Of the 32,408 inspections, 14,377 (about 44 percent) were programmed inspections. Programmed inspections focus OSHA’s…...
The purpose of the information collection requirements specified in the Permit-Required Confined Spaces Standard (29 CFR 1910.146) is to ensure that employers systematically evaluate the dangers in permit spaces before entry is attempted, and to guarantee that Start Printed Page 23725adequate measures are taken to make the areas safe for entry. Section 1910.146(c)(2) requires the…...
Hollywood has made a mockery of fixed fire protection systems. From showing sprinklers going off when the fire alarm is pulled to all sprinklers seemingly being “deluge systems“!!!! Well, finally we have footage of how a sprinkler system behaves. If you’re like me, you’ve sat in these restaurants and watched all the fires rage…...
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