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Did OSHA mean to define a non-PRCS differently in the Construction Standard?
Several years ago I wrote an article about how a space goes through its transitions to become a non-permit required confined space.  A space is not identified as a non-permit required confined space during its first evaluation; it becomes one after it has been “reclassified” using either (c)(7) or 1926.1203(g).  That article caused quite a stir with my readers, but most were convinced...
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What happens when the NH3 release inside the engine room exceeds 40,000 ppm?
UPDATED on 8/21/2019 with the 2018 IFC Commentary… I am guessing that someone has published a technical paper or article stating that an “electrical shunt” is no longer a code requirement for ammonia refrigeration engine rooms.  This has caused several of my clients and subscribers to ask me if this is true as this goes against some of my previous article where I reference the...
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Company Fined $220,000 for PRCS Accident that Left 3 Workers with Burns
A company was fined $220,000 by the State Courts today under section 12(1) of the Workplace Safety and Health Act (“WSHA”) for failing to take adequate safety measures for its work in an underground storage tank.  On 25 July 2016, four workers were instructed by their supervisor to clean an underground storage tank, a permit-required confined space 3.2m (10.5′) deep, that...
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Screenshot
How to annually verify my flammable liquid(s) processing area mechanical exhuast ventilation is functioning as designed
This $50 device is priceless in validating that the ventilation system is functioning as designed Verifying that a mechanical exhaust system provides sufficient airflow is critical for preventing the accumulation of flammable vapors. The use of a Vaneometer™ is ideal for monitoring low-velocity air currents (typically 25 to 400 feet per minute) at the face of hoods or exhaust inlets. This $50 device...
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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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