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Hot Work and an IMPAIRED SPRINKLER (and update FM HW Data Sheet)
In the PSM/RMP world, where Hot Work (HW) permits and all of 1910.252(a) are requirements, we tend to find HW programs, permits, and practices not meeting this critical requirement for SAFE HW.  This is caused by a wide array of errors, from the written program/permit omitting this requirement, training not covering this requirement, and/or personnel who issue the HW permits not being involved/informed...
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OSHRC to decide if welding in a CS makes that CS a PRCS
Does the cited provision of the welding standard (29 C.F.R. § 1926.353(b)(1)) presume that a hazard exists “whenever welding, cutting, or heating is performed in a confined space”?  CLICK HERE
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EPA RMP Amendment(s) UPDATE (May 2018)
On May 17, 2018, EPA’s Administrator signed a proposed rule requesting public comment on several proposed changes to the final RMP Amendments issued on January 13, 2017. EPA is proposing to rescind amendments relating to: safer technology and alternatives analyses, third-party audits, incident investigations, information availability, and several other minor regulatory changes EPA is also proposing...
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OSHA Cites Cosmetics Manufacturer Following November 2017 Fatal Fire
OSHA has cited a cosmetics manufacturer and proposed fines of $281,220 for failing to protect its employees from dangerous chemicals, and other hazards. In November 2017, OSHA investigated the cosmetics manufacturer after an employee was fatally injured in a fire. The company was cited for 11 violations for fall, and compressed air hazards, and for failing to ensure proper electrical grounding and...
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2018 Photo of the Week #19 (Summer time is here and so are the fans)
Spent most of April in TX and LA and the temps are climbing, and those “improper” fans are starting to pop-up.  This is NOT one of my photos, but it was shared with me.  It appears the exhaust fan died, so a pedestal fan was taken apart and mounted in the opening and then wired into a nearby breaker panel.  Let’s just agree this may not be quite up to code…...
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2018 Video of the Week #19 (Crane Collapse)
I just saw this one, not my video, but WOW!  
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EPA RMP citations @ ammonia cold storage facility (NH3 & $43K)
Respondent operates a cold food storage facility and has on-site for use, 14,000 pounds of anhydrous ammonia for cold food storage purposes. The respondent’s process is an RMProgram level 3 covered process. On March 29, 2017, the EPA conducted an onsite inspection of the RMProgram related records and equipment for the purpose of assessing the Respondent’s compliance with the RMProgram requirements...
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EPA RMP citations @ ammonia refrigerant facility (NH3 & $33K)
Respondent operates an ammonia refrigerant facility with 19,000 pounds of ammonia for food refrigeration purposes. The process is an RMProgram level 3 covered process. On March 24, 2016, the EPA conducted an onsite inspection of the RMProgram related records and equipment for the purpose of assessing the Respondent’s compliance with the RMProgram requirements and the implemented recognized and...
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2018 Video of the Week #18 (LOCK IT OUT!)
WARNING!  Viewer Discretion is advised; Video may be upsetting to some viewers.  
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EPA RMP citations (Flammables)
On or about August 22-23, 2017, EPA conducted an inspection (the inspection) of the Facility to determine compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68. Information collected as a result of the inspection revealed that Respondent failed to implement the risk management program at the Facility.  The following substances are a “regulated substance” according to 40 C.F.R....
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2018 Video of the Week #18 (FATAL HOT WORK EXPLOSION)
WARNING!  Viewer Discretion is STRONGLY advised as this video may be upsetting.  It shows a Hot Work Explosion and workers being thrown from the explosion and they perish in the accident. We should take heed when OSHA uses phrases like “certain”: 1910.252(a)(3)(i) Used containers. No welding, cutting, or other hot work shall be performed on used drums, barrels, tanks or other...
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2018 Photo of the Week #18 (Emergency Buttons-Hawaiian Style)
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