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EPA issues RMP citations @ ice manufacturing facility (NH3 & $182K)
Respondent owns and operates an ice manufacturing facility that typically operates 24 hours a day, seven days a week. On June 26, 2019, EPA performed an inspection of the Facility pursuant to Section 112(r) of the CAA, Sections 304-312 of the Emergency Planning and Community Right-to-Know Act (“EPCRA”), and Section 103 of the Comprehensive Environmental Response, Compensation, and Liability....
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Example of LATENT failures - Auditing
Many organizations have become very good at identifying the ACTIVE failures associated with an accident; however, in almost all of the accident investigations I have been involved with, I find LATENT failures to play a bigger role than active failures.  But that is a really hard pill for most organizations to swallow.  But there is a tool within our process safety management system that is...
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Air France flight 447 Crash - Technical Failures led to Human Errors
As the trial involving the fatal crash of Air France Flight 447 begins today, prosecutors will argue that Air France (the airline flying the plane) and Airbus (the manufacturer of the plane) are liable for their role in the fatal 2009 crash. Both companies face charges of manslaughter and negligence in the incident that killed 228 passengers and crew.   France’s air accident investigation...
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Butane Railcar(s) stored on a siding in NC found to be a stationary source under RMP
A North Carolina Administrative Law Judge found that railcars on a “siding” are a “stationary source,” as such, if they contain an EHS over the RMP threshold, they fall under EPA’s Risk Management Plan. This is in line with EPA’s recently proposed changes wanting to apply a 48-hour time frame to the term “storage, not incident to transportation” based on DOT and...
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Silent Killer in a Newly Constructed Manhole
Silent Killer in a Newly Constructed Manhole
OSHA received notification of a construction site fatality on August 5, 2004 – day following the incident Reported that the employee was found at the bottom of a manhole New sewer system under construction – SIC Code 1623                   … HomeRead More »
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GHS Rev.7 Physical Hazards
UN's GHS Rev.7 presentation
I am sharing this because OSHA is in the process of adopting Rev. 7 for their new HAZCOM standard, and if they do it, it will change the PSM application to some Category 1 Flammable Gases.               … HomeRead More »
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EPA Region 1 RMP Presentation
EPA Region 1 Chemical Warehouses and Distribution Facilities
EPA Region 1 RMP presentation. It has a lot about Ammonia refrigeration and some other EPA rules.   The presentation has a lot of actual pictures of violations.         … HomeRead More »
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Worker nearly died after co-worker turned on concrete mixer
A worker performing maintenance inside a cement mixer at a concrete manufacturing company narrowly escaped fatal injuries when a co-worker turned the machine on. An OSHA investigation determined that the company’s failure to comply with federal workplace safety standards nearly cost the worker their life. OSHA learned management knew that federal law required the company to train workers on lockout/tagout...
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PREVENTING Serious Injuries and Fatalities SIF Managing RISKS rather than Injury Rates
PREVENTING Serious Injuries and Fatalities (SIF) - Managing RISKS rather than Injury Rates (ppt)
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Human Performance Strategic approach to improving it
Human Performance - The strategic approach to improving it (ppt)
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Risk Management inside a SMS
Risk Management inside a SMS (ppt)
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EPA issues RMP citations @ frozen poultry storage facility (NH3 & $151K)
The Respondent operates a frozen poultry storage facility adjacent to other businesses, within several hundred feet of residences, and near a hospital. Respondent uses anhydrous ammonia in a refrigeration “process,” as defined by 40 C.F.R. § 68.3, in a system of pipes and vessels at the Facility (the “Process”). On June 5, 2019, EPA inspectors visited the Facility to assess...
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