I have joked about this topic in other posts, as we have been battling the idea that our new refrigerant for vehicle air conditioners is a Category 1 Flammable Gas. This conversion from R-134a has been a bumpy one, but in jest, I share with you EPA’s “use conditions,” and for an agency that certainly […]
The US Chemical Safety Board’s (CSB) most recent Safety Bulletin: Key Lessons from the ExxonMobil Baton Rouge Refinery Isobutane Release and Fire was once again a great piece of work by the agency. But as with most incidents, other underlying issues may have contributed (or not) to the incident. In this bulletin, I could not help but notice
The OSHRC sided with the company that used Appendix A from 1910.147 as their machine-specific LOTO procedure. They did so without any revisions to the content of the Appendix, and the OSHRC found this as an acceptable machine-specific LOTO procedure!
This case involved an industrial laundry company which uses continuous batch washers (CBW) which were correctly defined as a Permit-Required Confined Space (PRCS). During an OSHA inspection, the Compliance Officer (CO) took issue with the facility’s rescue plan from a CBW. After reading this case, I too took issue with their rescue plan; however, since
This OSHRC case involved laundry company who uses industrial sized washing machines which are correctly classified as a Permit-Required Confined Space (PRCS). OSHA inspected the facility, and the CSHO discovered that the calibration gas used to calibrate the direct reading meter that would be used for testing the atmosphere inside the continuous batch washers (CBW) has expired 18
I often review the OSHRC decisions to learn better the “legal” side of OSHA compliance and most of the time I find that the Review Commission is pretty much a straight shooter when it comes to applying OSHA standards. But there are times when I close my computer as if I just saw a ghost
At this year’s NSC Congress OSHA announced their 2017 Top 10 Violations. They have not updated their Data Page yet, but here are their preliminary…
Respondent is primarily engaged in the production of anhydrous ammonia, urea fertilizer, and urea ammonium nitrate, which includes two ammonia units (A1 and A2), a urea production unit, a UAN unit, and various ancillary units, including a carbon dioxide pipeline compressor station and a hydrogen recovery unit. Respondent produces, processes, stores, or handles more than
Back in early 2015, I began working with some clients who were questioning their having to enter into the Process Safety arena because of a new refrigerant that was going into automobiles. Early in our discussions I was appalled that this flammable refrigerant had been “marketed and sold” with the description of being a “mildly flammable”
