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An emergency alarm system at a PSM/RMP facility and NFPA 72
Those in the PSM/RMP world know that the facility is REQUIRED to have an Emergency Action Plan (1910.38) and by virtue of having to comply with 1910.38, we also have to comply with 1910.165 Employee Alarm System. The language in 1910.165 is really vague and causes much confusion when it comes to the emergency alarm system initiating means, especially when asked: “how many pull stations do I need?” Here...
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Why is a medical evaluation necessary for those wearing a respirator?
Breathing… we do it all day long, every day, and yet we never even put a thought to it.  But so many respirator users do not understand the basics of how we get the air (more importantly, the oxygen in the air) into our lungs so that it can enter our bloodstream for survival.  As I said, breathing is an involuntary act – meaning we are not sucking air into our lungs.  In...
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Why are the pressure vessels in my PSM/RMP covered processes managed differently than those "every day" type pressure vessels?
Recently I had a client who made alterations to a pressure vessel (PV) in an ammonia refrigeration process that required the PV to be re-certified. The state where this PV resides is a “coded state”, meaning they have adopted ASME Code for the PVs within the state. So, the contractor making the alterations had scheduled the Authority Having Jurisdiction (AHJ) (in this case it was an insurance...
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Is API 570 your Piping Inspection/Repair RAGAGEP... Repair Requirements are now crystal clear
If API 570 is your facility’s piping inspection/repair RAGAGEP, the battle over “repair requirements” just got easier!  A very popular question in PSM/RMP circles has become… “Do we have to make repairs in the same manner as we did the initial install of the pipe?” In other words, what is being asked is… “Can we bypass some of the ASME B31 requirements...
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Safety Starts with You ( SafeWork NSW)
 
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Isothermal Lines 1 Day Mean Temps
MDMT and Atmospheric Temps
In my travels to our friends north of the US border, it is not uncommon to find “used vessels” in service that were never intended to be used that far north and for the record, this occurs in the USA northern states as well.  The figure below is one that is used by many to establish the Minimum Design Metal Temperature (MDMT) of their vessels based on where in North America the vessel...
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OSHA's position on flammable liquids (.106) and PSM (.119) with regard to PD pumps in a process
Scenario 1: The first scenario you described has the following attributes: Your firm is engaged in the design and construction of a manufacturing (processing) facility which includes OSHA Category 2, 3, and 4 flammable liquids as raw materials and processing intermediates. The Food and Drug Administration and countries in Europe, the Middle East, and Africa regulate the facility due to the manufacture...
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Is your Pulmonary Function Testing (PFT) being performed by "qualified personnel"?
Another aspect of a “respiratory protection program” often times will include a PFT as part of the “medical evaluation”.  For the most part, these PFTs are done by the location where the PLHP resides and most of the time they are done by “trained” personnel – but how many of us actually audit the service provider to ensure they hold the proper certifications?  OSHA’s...
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What does OSHA now require for annual submittal of Injury and Illness data?
I have received a number of e-mails, text, and phone calls concerning OSHA’s change in their Electronic Filing of Injury and Illness data.   Bottom Line… 300A Annual Summary Data is all that is required to be submitted for those establishments that have 250 or more employees.  TIP: “employees” are that personnel on site that if they were to get injured would,...
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N2 dewarsspa
Nitrogen Dewars @ Spa and the OH Fire Code
Fire Codes mean something… at least in our world of occupational safety and health.  As I was entering a restaurant for dinner, I am checking out my environment and what do I see but two (2) dewars of Nitrogen in some kind of “float spa”.  This was in a “strip mall” type setting so of course, my curiosity got the best of me.  Nitrogen is one of those...
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Catastrophic failures of SCBA cylinders
On July 11, 1996 a member of the Roxbury Township, Morris County, Fire Department, Firefighter Paul Label, age 29, was in the process of recharging an aluminum 2216 psi SCBA cylinder from the department’s cascade system at about 2038 hours, when it failed catastrophically resulting in serious injuries to Mr. Label. On October 8, 1996 a similar failure of an aluminum 2216 psi SCBA cylinder resulted...
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OSHRC LOTO decision on "unexpected start-up"
WOW… just WOW!  I feel like I am in the twilight zone after reading this decision.  I am not a big fan of government shutdowns, but right now, I wish the OSHRC would get shut down.  It is rare, but it does happen when I take serious issues with decisions of the OSHRC, and this one has to be one of the worst ever.  Imagine this scenario… An Electrified Monorail System...
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