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OSHA PSM citations @ paper product manufacturer (ClO2 & $211K)
OSHA cited a paper product manufacturer for exposing employees to hot steam and failing to ensure the use of proper hazardous energy control methods. The company faces $211,400 in proposed fines.  OSHA launched an investigation of the facility after hot steam burned an employee trying to repair a leak on a steam-line header.  OSHA determined the header had been leaking for several...
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OSHA PSM citations @ poultry processing facility (NH3 & $119K)
OSHA has cited a poultry processing company $119,341 for exposing employees to hazardous chemicals. On January 27, 2019, 12 employees needed transport to nearby hospitals after a leak caused the release of 2,100 pounds of anhydrous ammonia. OSHA cited the company for failing to provide an operable alarm responsible for indicating the release of hazardous chemicals. OSHA also cited the facility for...
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2019 edition of the National Board Inspection Code (NBIC) summary of major changes
The 2019 edition of the National Board Inspection Code (NBIC) has been available for purchase since July 1st, 2019.   Here is a summary of the major changes: … HomeRead More »
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NH3 hydro expansion event
Anhydrous Ammonia hydrostatic expansion event?
This is another picture that was shared with me and is making the rounds on social media.  It certainly appears to be a liquid (hydrostatic) expansion event on a stainless steel pipe.  The story goes and I can certainly see this happening…  Valve installed when hot out. Valve didn’t fully seat and allows vapor to pass into the lower pressure where it condensed when it got cold...
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Pressure Test gone bad
Hazards of Improper weld repair and failed hydrostatic pressure testing?
I have many questions about this picture but was told this was the results of a failed hydrostatic pressure test after a non-certified repair was made.  Has anyone seen this picture before?  Got an incident report to go along with the image?  My source is very trustworthy, but I just would like to have an incident report that goes with this picture.  I have checked the National...
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Toluene applied in a 10' X 8' X 5.5' pit using an APR as protection (PRCS Fatality - O2 Deficiency)
Another example of not understanding the chemical hazards in your CS/PRCS… This OSHA case shows us that “pits”, even those that would are not identified as a PRCS in a site evaluation can be deadly from the work we do inside them! When using a chemical that has a Vapor Density 3X’s that of air (1) inside a 10′ deep pit is creating both a FLAMMABLE ATM and in this...
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Dispelling the myth... entry into a PRCS requires ventilation
I am guessing that maybe we should have had the “Top 11 Myths” rather than the “Top 10 Myths” in our presentation at Safety2019!  I continue to get emails from folks who want to convince me that “ventilation is required for all entries into PRCSs”.  I have even had a face-to-face discussion with an OSHA CSHO from a State Plan who informed that it was required...
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What is the FAMILY SAFETY STANDARD to work and live by?
I was always taught from my very first Plant Manager the “standard of safety/risk” is FAMILY.  When that manager/supervisor would not think twice of having one of their family members work in their department/unit, they have then achieved the FAMILY SAFETY STANDARD. Now I am not talking about their children, but if they had a teen daughter or son, who was physically capable of doing...
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FM approved deadman flammableliquids
What is an approved self-closing valve?
This week I posted the requirement for transferring a flammable liquid using “gravity”.  This requirement comes from OSHA’s flammable liquid standard… 1910.106(e)(2)(iv)(d) flammable liquids shall be drawn from or transferred into vessels, containers, or portable tanks within a building only through a closed piping system, from safety cans, by means of a device drawing...
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Transferring flammable liquids without a deadman valve can be deadly indeed!
There is a sound reason why OSHA’s Flammable Liquid Standard has required a deadman valve for over 40 years and it is the same reason why I have written about their use for 20 years… When things go bad and you need to get the heck out of dodge quickly, you can do so AND stop the flow of the flammable liquid. 1910.106(e)(2)(iv)(d) flammable liquids shall be drawn from or transferred into...
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EPA RMP GDC citations @ windshield wiper fluid manufacturing facility (Methanol & $197K)
PLEASE NOTE this case is significant in that many facilities in the OSHA arena will EXEMPT their “methanol” from PSM coverage using the “Atmospheric Storage Tank” exemption (e.g. 1910.119(a)(1)(ii)(B) or called the “Meer Decision”).  EPA couldn’t care less about this OSHA exemption, as is evident in this case! There is NO EPA RMP exemption...
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Positive Isolation
International methods of Energy Isolation (RISK BASED - SG253)
Since I shared my article last week on OSHA’s position of NOT allowing “exclusive control” to be carried over to process valves like we do with “cord and plug” electrical equipment, my international friends and clients have been having quite the chuckle at us here in the USA.  They all say virtually the same thing… “you guys sure do make something so simple,...
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