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PSM 2022 Most cited by of citations not sowing data
Detailed breakdown of PSM inspection data for 2022
In my earlier post, my data showed OSHA conducted 66 PSM inspections and issued 347 citations.  Now that I have all the data in raw form, I saw 430 citations in 2022.  The discrepancy is likely due to one database using the “issuance date” and the other using the “final order” date.    And yes, SOP citations were #1 in 2022, beating the all-time reigning...
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Safe Work Practices, Operating Procedures and Maintenance Procedures are a STARTING POINT!
Maybe I’m just old school, but is it just too much to ask for: a well written safety procedure, one that is written and analyzed with a safety pro and the worker(s) who do the actual work, that management will fully support the procedures everyday-everytime, including on holidays that fall on a Sunday, and employees will follow procedure everyday-everytime, including on holidays that fall on a Sunday? There...
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EPA RMP GDC @ ice rink facility (NH3 & $6K w/ Plan)
Respondent operates an ice rink facility with an ammonia refrigeration system. The System uses or used anhydrous ammonia, a chemical that is listed pursuant to Section 112(r)(3) as an “extremely hazardous substance” and that is subject to the General Duty Clause. In March of 2022, Respondent’s response to an Information Request issued by EPA revealed that Respondent had failed to...
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EPA RMP Citations @ animal slaughtering facility (NH3 & Compliance Plan)
Respondent is the owner and/or operator of an animal slaughtering facility where anhydrous ammonia is used in refrigeration systems. The Respondent conducted an offsite consequence analysis in early 2022, showing that the population inside the worst-case scenario radius includes 961 houses, and 2,851 people could be exposed to this release. The Respondent also conducted an alternative release scenario...
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EPA RMP Citations @ ingredients facility (EO and N(CH₃)₃ & Compliance Plan)
Respondent is the owner or operator of an ingredients facility with greater than 10,000 pounds of ethylene oxide in a covered process and greater than 10,000 pounds of trimethylamine in a covered process at the Facility. From the time Respondent first had onsite greater than 10,000 pounds of ethylene oxide and/or trimethylamine in a process, Respondent was subject to Program 3 prevention program requirements...
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EPA RMP Citations @ chemical distribution facility (Formaldehyde & $125K)
The Respondent owns or operates a chemical distribution facility where the respondent has used or stored more than 15,000 pounds of formaldehyde. 40 C.F.R. § 68.25(a)(2)(i) requires the owner or operator of a stationary source to analyze and report in a Risk Management Plan (“RMP”) the worse-case release scenario that is estimated to create the greatest distance in any direction to an endpoint...
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PRCS Fatality (HAZ ATM); 1 entrant and 1 would be rescuer
On June 7, 2022, an employee working as an environmental engineer was replacing two failed pumps in a pump station. Two coworkers connected the new pumps to electricity, and the employee lowered the pumps into the vault. It was noted that the pumps weren’t working correctly, and water was pumped from the space. The employee was allegedly overcome by hydrogen sulfide (H2S), fell into the vault,...
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Human Factors - Failed Checklists
Northwest Airlines Flight 255, a McDonnell Douglas MD-82, crashed in Romulus, Michigan, shortly after takeoff from Detroit Metropolitan Wayne County Airport on August 16, 1987, at about 8:46 p.m. It killed all six crew members and 148 passengers, and two people on the ground. There was only one survivor, it was a 4-year-old girl who sustained serious injuries. It was the second-deadliest aviation...
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CFATS by the numbers on its 15th Anniversary
November 20, 2022 was the anniversary of Chemical Facility Anti-Terrorism Standards (CFATS) regulations.  And although it is not as well known as OSHA’s PSM and EPA’s RMP standards, it is a standard that many PSM/RMP practitioners deal with, so I thought it would be fitting to look at the CFATS numbers… … HomeRead More »
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EPA offers insights into "Responding Facility" vs. "Non-Responding Facility"
In a recent training course, the EPA answered the “One Big Question”… (one that I have written about many times) Does the facility rely on emergency responders to stop the release of the regulated substance(s)? If the facility answers Yes, they are saying the local first responders will respond and stop the release.  This means the facility is responsible for the following: Comply...
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EPA RMP triggers to have your case referred to DOJ
Here are the six (6) triggers that will get your RMP Inspection Case referred to DOJ: … HomeRead More »
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Fish holds on commercial fishing vessels (H2S)
This Safety Alert addresses the importance of verifying atmospheric conditions in fish holds on commercial fishing vessels. There are specific hazards associated with the use of brine dip solutions, a common substance used in the industry. Brine dip combined with standing water can produce dangerous levels of hydrogen sulfide (H2S). The U.S. Coast Guard is currently investigating a marine casualty...
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