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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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1910.137 Table I 5 2
OSHA clarifies the 6-month testing frequency of Rubber Insulating Electrical Gloves (1910.137)
One of the more common deficiencies that we find in our audits is the lack of electrical gloves testing.  1910.137, Table I-5 establishes the testing frequency for these gloves; however, the confusion comes with the “footnote” which states… If the insulating equipment has been electrically tested but not issued for service, the insulating equipment may not be placed into...
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EPA RMP citations @ LPG and Butane facility
Respondent owns and operates a liquefied petroleum gas plant which handled and handles a maximum of approximately 3,548,000 pounds of propane and 761,400 pounds of butane at the Facility. EPA conducted an inspection of the Facility on October 17, 2018 to determine Respondent’s compliance with CAA Section 112(r)(l) and (7) and the Chemical Accident Prevention Provisions at 40 C.F.R. Part 68. Respondent...
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Benchmarking Risk by Whole Room Scale Leaks and Ignitions Testing of A3 Refrigerants
The objective of this project was to conduct refrigerant R-290 (propane) leak and ignition testing under whole room-scale conditions to develop data and insight into the risks associated with the use of Class A3 Refrigerants and to generate technical data to support revisions of relevant safety standards.       The entire project included parametric testing to investigate how key...
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TSSA Canada- Cell Phone Use at Gas Station Dispensers, 1 in a billion chance
SAFTENG NOTE:  Please do NOT misunderstand what is being said here.  This study was in NO WAY an endorsement that cell phones are safe for hazardous locations.  What is being said, is that cell phones do not cause gasoline fueling fires; which we have debunked that myth here for over a decade.  Static electricity generated by the person fueling their car is the ignition source for...
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UDF PRCS3
When the Condenser manufacturer is telling you their equipment is a Permit-Required Confined Space
This week I was at one of my food clients who use anhydrous ammonia as their refrigerant.  This client replaced two old condensers with one bigger condenser. This new condenser came with some interesting labels, which to safety professionals, made our “assessment” of this piece of equipment relatively easy… it is a Permit-Required Confined Space.  Now, if we could only get...
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Confined Spaces and Limited or restricted means for entry or exit
Since our presentation at ASSP Safety2019! I have been getting the strangest request for clarification on how OSHA views “limited means of egress” and for the life of me, I just can’t understand why.  Yes, the GI standard for PRCS’s (1910.146) does not define the phrase; however, since 2015 OSHA’s Construction Standard for PRCS has actually defined the phrase quite...
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Confined Spaces and Limited or restricted means for entry or exit
Since our presentation at ASSP Safety2019! I have been getting the strangest request for clarification on how OSHA views “limited means of egress” and for the life of me, I just can’t understand why.  Yes, the GI standard for PRCS’s (1910.146) does not define the phrase; however, since 2015 OSHA’s Construction Standard for PRCS has actually defined the phrase quite...
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braille under glass 45773
Human Factors 101 - #1002 Signs
When you try to include the disabled in your business and then someone wants to get fancy and upgrade the place with glass over the signs… … HomeRead More »
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braille under glass 45773
Human Factors 101 - #1002 Signs
When you try to include the disabled in your business and then someone wants to get fancy and upgrade the place with glass over the signs… … HomeRead More »
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Human Factors 101
Human Factors 101 - #1001
I am not sure why I am so fascinated with the Human Factors aspect of process safety, but I blame my pals Bob and Steve at Unwin Company for beating it into my head during the first PHA I did with them way back in 1999.  They ripped me apart with how our procedures were written and taught me so much (still do today) about human factors in process safety (20 years and still learning!).  But...
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