This posting includes some very interesting citations issued by EPA (not OSHA). For example, EPA took issue with using “pink ribbons” on valves being used in an energy isolation for contractors installing a piece of equipment – rather than LOTO locks or tags! This “ribbon” idea is still fairly prevalent in the refrigeration industry still today, as evident by recent discussions in some social media refrigeration forums. Take note, even EPA knows “pink ribbons” (or any color ribbon for that matter) tied to valves being used for energy control is NOT an acceptable means of LOTO! The other aspect of this case is the fact that it was a General Duty Clause (GDC) case, but EPA pulled out all the stops and many of these citations are the type that would be issued to a process that exceeds the RMP threshold(s) (e.g. 10,000 pounds for NH3); although this process had only 6,275 pounds. Heck EPA even referenced the newest editions of IIAR 2 and ASHRAE 15 for a process that was built well before their publication. A table is provided with all the citations and referenced RAGAGEPS for SAFTENG members. I should also point out that EPA used NFPA codes, State Fire Codes, OSHA stds, and several NH3 refrigeration RAGAGEPS in their citations.