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The State of Missouri seeks to be the "delegated enforcement authority" for NH3 RMPs
This rulemaking requires the Air Conservation Commission to develop a state rule and accept delegation from the EPA. This rulemaking will lay the groundwork for the Agricultural Anhydrous Ammonia RMP Compliance and Enforcement program. Once delegated, the oversight for the RMP program will transfer from EPA to DNR. The benefit of this rulemaking affects the agricultural community in the State of M...
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OSHA's progress in revising the PSM Standard
The Occupational Safety and Health Administration (OSHA) issued a Request for Information (RFI) on December 9, 2013 (78 FR 73756). The RFI identified issues related tomodernization of the Process Safety Management standard and related standards necessary to meet the goal of preventing major chemical accidents. OSHA completed SBREFA in August 2016. OSHA held a stakeholder meeting on October 12, 2022,...
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A great tool to assess your current SMS
You can assess your own health and safety management system using this self assessment checklist (.doc) . Use the columns in the middle of the table to give yourself a score for each element.  Where you give yourself a score of 1 or 0 you may need to take action to improve those elements – note this in the right hand column. Where you award yourself a score of 2 it means you are doing well. If...
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Managing Organizational Changes
All changes to an organizational structure or changes in personnel with specific Knowledge, Skills, Experience, and Behaviors (KSEB) must be assessed to understand the impact of the organizational change on safety. Any organizational change has the potential to introduce safety hazards and risks, and therefore, all changes to an organizational structure or changes in personnel with specific KSEB must...
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Managing Changes using the "Plan, Do, Check, Act" management system approach
The systematic process to manage any change should follow the “Plan, Do, Check, Act” approach. This should start at the planning stage BEFORE: the change has been fully developed, continued and monitored during the change process and reviewed after it has been implemented. This systematic approach applied to all changes to equipment, infrastructure, policy, or the organization must include:...
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Human Factors Considerations in Commercial Human Space Flight
Although this advisory circular is for Commercial Human Space Flight, it can be applied to High-Risk activities in an industrial setting, such as process safety matters. The single most significant gap I see in past PHAs is the Human Factor(s) analyses. In some cases, I cannot even recognize the methodology used in the PHA. In the year 2024, it is about time we begin to take the HF analysis and the...
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Time Frame to Submit RMP Emergency Contact Information Changes
How much time does the owner or operator of a stationary source have to submit a correction to a Risk Management Plan when the emergency contact information changes? … HomeRead More »
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Safety Thought of the Week... LATENT ORGANIZATIONAL failures and accident causation
It is suggested that LATENT ORGANIZATIONAL failures are analogous to the “resident pathogens” within the human body, which combine with external factors (stress, toxic agencies, etc.) to bring about disease. Like cancers and cardiovascular disorders, accidents in complex, defended systems do NOT arise from single causes. They occur through the unforeseen (and often unforeseeable) concatenation...
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EPA RMP citations @ ice cream plant (NH3 & $93K)
This EPA CAFO has me wondering who upset the U.S. EPA. There are only two (2) violations; one is the most cited RMP violation in the past seven years and is quite minor; the other was one of the newest RMP requirements, and those two violations netted a $93,000 citation. Respondent is the owner and operator of a facility that operates a refrigeration process that uses Anhydrous Ammonia in quataties...
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OSHA states "pre-charged air conditioners and heat pumps” in a warehouse or distribution center are subject to 1910.119, if the aggregate weight of the refrigerant, a flammable gas,on the premises exceeds the threshold quantity (TQ) of 10,000 pounds
On May 6, 2021, the Environmental Protection Agency (EPA) published a Final Rule listing R‒452B, R‒454A, R‒454B, R‒454C, and R‒457A as acceptable substitutes, subject to use conditions, for use in residential and light commercial air conditioning and heat pumps. These refrigerants are flammable and are classified as belonging to ANSI/ASHRAE Standard 34 safety group A2L. The listed substitutes are refrigerant...
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The use of a sulfur stick (NH3 leak detection) is hot work (1910.119(k) LOI)
A few weeks ago, I gave a sneak peek at what was coming: Manufacturer’s Limitations of Sulphur Sticks. Today, it arrived in the form of an OSHA LOI.  A sulfur stick is a tool used to find ammonia gas leaks. Sulfur sticks, when burned, react with ammonia gas to make a visible smoke and are generally used near process equipment and piping to detect leaks. The company has an established procedure...
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Electrical equipment certified by an organization that is NOT an OSHA Nationally Recognized Testing Laboratory (NRTL)
Does all fixed/portable/mobile equipment that is installed or enters a Hazardous Location (HAZLOC) have to be “certified” and “labeled” as being acceptable for that specific HAZLOC? The blunt answer is YES! But in today’s working world and global economy, I am seeing a lot of foreign approvals for electrical equipment that is not by one of OSHA’s NRTLs. I am also,...
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