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January 21, 2023
In OSHA’s fiscal year 2022, Process Safety Information, was the #3 most cited element of the PSM standard. Here is a breakdown of those citations…
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January 21, 2023
In OSHA’s fiscal year 2022, Mechanical Integrity (MI), was the #2 most cited element of the PSM standard. Here is a breakdown of those citations…
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January 21, 2023
OSHA’s fiscal year 2022 saw a significant change in the leading PSM element for citations. As far as I know, Mechanical Integrity has been the most cited element every year for the past 20 years. And it held that spot convincingly for those years. Last year, SOPs took the top spot with…
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January 21, 2023
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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January 21, 2023
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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January 20, 2023
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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January 20, 2023
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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January 20, 2023
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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January 20, 2023
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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January 20, 2023
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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January 19, 2023
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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January 18, 2023
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…
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