Safety Info Posts

Can a facility alter its highly hazardous chemical storage practices to avoid PSM?

Yes. When OSHA enacted the PSM requirement, it did so in an effort to eliminate or minimize catastrophic incidents involving highly hazardous chemicals. PSM programs are risk reduction strategies. When implemented correctly, reducing storage inventories of highly hazardous chemicals and isolating stored quantities in distinct facility areas are acceptable risk reduction strategies. Employers at storage…...

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OSHA publishes DRAFT “Process Safety Management for Small Business Compliance”

UPDATED 4/19/2017 – OSHA has published the approved edition https://www.osha.gov/Publications/OSHA3908.pdf OSHA has published a DRAFT revision of their OSHA 3132, Process Safety Management.  This new version is NOT meant to be a replacement for OSHA 3132, but instead meant to be a companion to the original OSHA 3132 specifically for small businesses that may be impacted by…...

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Cal/OSHA has cited a metal processing company $73,105 for serious PRCS violations

Cal/OSHA has cited a metal processing company $73,105 for serious safety violations following a March 13, 2016 confined space accident in which a worker was asphyxiated.  Cal/OSHA investigators found the company failed to comply with confined space regulations that resulted in the serious illness. On March 13, a supervisor sent an untrained production assistant into a…...

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Ammonia Refrigeration, Diffuser Tank and Uniform Mechanical Code (UMC)

The diffuser tank discussion continues and Peter Thomas, P.E. from Resource Compliance, Inc. was kind enough to offer us the following insight as to when a diffuser tank would be required.  In most of my postings, I reference the International Fire Code (IFC) and International Mechanical Coden(IMC) quite often, but the Uniform Mechanical Code (UMC) is a…...

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Ammonia Refrigeration, Diffuser Tank and NFPA 1

This past week I was having a conversation with my friend and fine PSM professional Brian Chapin @ RCE and our discussion turned to diffuser tanks.  Having been involved in several design and install projects over the past several years, getting to know a little something about diffuser tanks comes with the territory.  But one of my…...

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Another example of why our Line Break Permitting should cover MORE than just our PSM/RMP covered process(s)!!!

This incident shows us that just because a pipe contains a chemical that may not be included in a PSM/RMP program, it does not mean the level of risk is any less.  This explosion was caused by construction workers using a cutting torch to remove old piping from a boiler room and cut into a…...

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Fire Extinguisher used as an “air receiver” catastrophically fails and claims three (3) legs!!!

A fire extinguisher is often times looked upon as a safety device and therefore many overlook these devices potential hazards.  It is true, they can save lives, but they can also take lives and limbs as was the case in this accident.  Back in February, as I reported in the Incident Alerts, two workers were…...

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Machine guarding CNC Mills and Lathes (OSHRC Decision)

This case is significant in a number of ways:  1) manufacturer of the equipment put warning signs on their machines pointing out the hazard(s), 2) manufacturer considered the “doors” on their CNC mills and lathes to be “guards”, 3) manufacturer installed interlocks on the “doors” (i.e. guards), 4) company bought the machines “used” and many of the interlocks were not operational at…...

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Fertilizer Canada has gotten serious about Facility Siting for NH3 Ag facilities!

2016 will go down as the year OSHA and EPA tried to revamp their PSM and RMP rules for handling Highly Hazardous Chemicals (HHC) and Extremely Hazardous Substances (EHS).  We have even seen Congress get into the act of blocking OSHA from enforcing PSM on fertilizer distributors.  All the while, our friends to the north have…...

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Did the Federal Motor Carrier Safety Administration (FMCSA) just declare e-cigs an “ignition source”?

No, not directly, but they did issue this Safety Advisory: Possession or Use of Battery-Powered Portable Electronic Smoking Devices Around, On or While Operating a Commercial Motor Vehicle (CMV) relating to the possession and use of battery-powered portable electronic smoking devices (e.g., e-cigarettes, e-cigs, e-cigars, e-pipes, e-hookahs, personal vaporizers, electronic nicotine delivery systems (ENDS).  In this Safety Advisory, the…...

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Post-Accident Drug Testing and OSHA’s New Reporting Rule

This past week I worked with a client who’s safety contact is the HR manager and we had several discussions about OSHA’s revised recordkeeping requirements and all the recent reporting changes.  One thing I noticed is that ALL MANUFACTURING facilities are considered “high risk” and are on the list of NAICS’s number that must report.  So the…...

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