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ASSE session 1
My 4-part series on PRCS's at the SW OHIO ASSP
SAFTENG members, here are four ppt files that I used at my four-part series I did the past four months at the SW OH ASSP Chapter meetings.  We broke the sessions down into:  Evaluating spaces What makes a space a CS What makes a CS a PRCS Entry options (c)(5) Alternative Entry  (c)(7) Reclassification (d)-(k) Permitted Entry PRCS Entry Program and Permit Requirements Rescue Non-Entry...
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Don't let fools scare you! EPA RMP 3rd Party Compliance Audits
Yes, as I posted a couple of weeks ago, the RMP Amendments are now in effect (at least those with compliances dates that have passed – some have dates further out).  One such requirement that seems to be causing a stir is “3rd Party Audits” for Program 2 and 3 Level RMP processes (e.g. 68.59 and 68.80).  LinkedIn and other social media platforms have less than scrupulous...
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Do you call this Tagout or is it a Lockout Exception
In this last part of 2018, I have been on a LOTO crusade; I have been to 12 different facilities since August to help them understand LOTO.  Some projects were complete new builds, some were to help with implementing Group LOTO, and a few were to training company safety professionals on the OSHA requirements so they can better understand the minimum requirements.  But not just over these...
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Ammonia release caused by a "recalled" solenoid valve not being addressed
UPDATE:  Earlier this year I posted a news account of an NH3 release in Cincinnati because of statements from a VP of the company stating an “explosion had occured”.  I have since learned that yes it was an “explosion”, but not one involving fire as so many think of when they hear that word. From a preleiminary investigation, it is looking like the NH3 leak from a...
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PSM/RMP "Inspection of Buried Process Piping"
Inspection of buried process piping is different from above ground process piping because significant external deterioration can be caused by corrosive soil conditions and the inspection is much more difficult due to the inaccessibility of the piping.  However, as difficult as it may be, buried piping MUST be inspected to determine its external surface condition. The facility has to develop an...
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The differences between ASME B31 series and API 570 series
I was recently reminded of how so many in process safety struggle to see their process(s) thru different lenses based on the piping’s life cycles. Using ASME B31.3 and 31.5, we see that these codes (e.g. RAGAGEPs) are design and build piping standards. Looking at API 570 series we see these are codes (RAGAGEPs) for the inspection of “in-Service” piping. Yes, both have pressure testing...
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OSHA 2018 citations in NAICS Code: 493120 Refrigerated Warehousing and Storage
In OSHA’s 2018 fiscal year it conducted 28 inspections at Refrigerated Warehouses and Cold Storage facilities.  This resulted in 84 citations being issued, totaling $426,241.  The Top 10 Standards OSHA found issues with were: … HomeRead More »
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2016 2017 2018 PSM Inspection Trends
2016, 2017, 2018 PSM Inspection Data Analysis
I received a number of requests today regarding questions about the 2018 PSM Inspection Data I posted last night.  Mostly, members wanted to see a comparison to previous years data.  So here is the comparison of charts/graphs for the SAFTENG members that include 2016, 2017 and 2018 data for # of Inspections, # of Citations, and the Citation $  This is nothing fancy, but quite...
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OSHA's 2018 Respiratory Protection Citations (By NAICS)
In OSHA’s fiscal year 2018 the agency performed 1,154 Respiratory Protection Inspections, resulting in 2,599 citations worth $3,228,420.  The top 5 industries accounted for 176 of these inspections, 460 citations, and $377,748 in penalties. Total for all industries and the Top 5 industries shown in the table below. Also, below is a breakdown of all 2018 Respiratory Protection citations...
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OSHA's 2018 PRCS Citations (By NAICS)
In OSHA’s fiscal year 2018 the agency performed 148 PRCS Inspections, resulting in 358 citations worth $1,520,294. The top 5 industries accounted for 25 of these inspections, 84 citations, and $343,738 in penalties.  Total for all industries and the Top 5 industries shown in the table below.  Also, below is a breakdown of all 2018 PRCS citations by the NAICS, their $ amounts, and the...
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OSHA's 2018 LOTO Citations (By NAICS)
2018 was a busy LOTO year for OSHA, with 1,464 LOTO Inspections, resulting in 2,657 citations worth $13,860,475. The top 5 industries accounted for 257 of these inspections, 463 citations, and $2,192,163 in penalties. Citations Inspections Penalty Industry Classification 105 56 $396,777 32192 / Wood Container and Pallet Manufacturing 102 59 $340,169 33271 / Machine Shops 90 48 $318,879 32311...
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OSHA 2018 citations in NAICS Code: 311 Food Manufacturing
Listed below are the standards which were cited by Federal OSHA for the specified NAICS Code: 311 Food Manufacturing during the period October 2017 through September 2018. Penalties shown reflect current rather than initial amounts. Summary: The Food Manufacturing Sector was inspected 554 times and received 1,609 citations totaling $7,511,783 in citations. The top five (5) standards cited in this sector...
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