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HAZWOPER training credentials - it ALL matters!
There are not very many OSHA standards that call out the “trainer qualification(s)” for those who teach on the subject matter, but the HAZWOPER standard does.  When a trainer uses the phrase HAZWOPER over and over but does not recognize this is an acronymn that stands for Hazardous Waste Operations and Emergency Response, has no emergency response background, and/or has never received...
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OSHA's official position on LOTO-AFFECTED PERSONNEL
WOW… my LOTO ppt for “Affected Personnel” that I posted earlier this week has caused quite the “back and forth” with too many people/sites.  I just assumed that we had a basic understanding of “who falls into the “affected” bucket” and “what they must know”.  Affected employees do NOT need to attend a 2-hour training course...
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NFPA 51B - 2019 Updates to Fire Watch and Fire Monitoring Requirements
Many of us in the PSM/RMP arena use NFPA 51B as our Hot Work Safety Standard, rather than 1910.252(a) and with that said I thought I should update us on NFPA’s 2019 edition of 51B which includes several key improvements.  Probably the biggest changes from the 2014 edition are: the term FIRE WATCH is now officially defined, the FIRE WATCH TIME PERIOD after completion of hot work...
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Emergency Pressure Control Systems (EPCS) and Car Seal Program
One phrase that drives me crazy while working with my friends in the Ammonia Refrigeration industry is, “Come on, Bryan; we’re not a refinery or chemical plant; that is unnecessary here.”  For example, recently, we were asked to aid in an investigation into a reportable release from a PSM/RMP-covered process, and during our review of what happened, the facility failed to mention...
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LOTO Affected Personnel Training (.ppt)
   
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OK is just NOT good enough in Safety
We all know we, as safety professionals, see life through a different lens than most others.  But ever since I started seeing these AT&T commercials “Ok is just not good enough” I always go back to my HAZMAT ER days.  One of the last ER’s I was called upon for assistance, I was delegated to a non-official position because the local powers made it clear “we...
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EPA RMP citations @ food plant (NH3 & $34K)
Respondent operates an ammonia refrigeration plant and has on-site for use, 130,000 pounds of ammonia for cold food storage. Respondent has submitted and registered an RMPlan to the EPA for its stationary source and has developed an RMProgram accidental release prevention program for the stationary source’s single RMProgram level 3 covered process. On November 8, 2017, the EPA conducted an onsite...
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The magic of Carbon Monoxide... Chemical Asphyxiant (Video)
You are the entry supervisor for entry into a Carbon Monoxide (CO) Tank.  Your meter is equipped with an Oxygen Sensor, but it does NOT have a CO sensor.  You proceed with your atmospheric testing, as you were told years ago that as long as the Oxygen was over 19.5% that all will be OK.  What you do not know is that CO is a “magic asphyxiant”, technically called a “Chemical...
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Today could have been hell... what are we starring at?
We have an uncontrolled release from our PSM/RMP covered process today, February 5, 2019.  We have trained for this day.  We have inspected our gear, well most of it, each month for years.  We don our LEVEL A suits, which have been pressure tested annually and cared for per every single manufacturer’s requirements.  Under our LEVEL A’s, are our SCBAs; again inspected...
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EPA's RMP and Ammonia Refrigeration
UPDATED on 2/6/19, based on feedback from my friend and Refrigeration PSM Extrodinare Brian Chapin over at RCE (A former Partner in Safety).  I have shared his analysis and my rebuttal/agreement… By a long shot, these are the top three (3) issues found with Ammonia Refrigeration RMPs: The NH3 is “Liquified by Pressure” – not by refrigeration! Process Purgers are NOT the...
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OSHA Inspections: Regional Emphasis Program on Ammonium Nitrate
This 10-minute video provides an overview of the OSHA inspection process under the agency’s Regional Emphasis Program for Fertilizer Grade Ammonium Nitrate and Agricultural Ammonia Facilities.  
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LOPC... just four letters but they mean SO MUCH to process safety engineers
One of my favorite parts of teaching the 1-day PSM Intro course at ASSE SeminarFest is the vast numbers of students and all of their learnings and experiences being shared. This year was even better than years before – in fact, we had so many side-bar discussions because of the great input from the students – that I ran out of time (also due to a 90-minute lunch break this year). The one...
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