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A sneak peek @ EPA's Revised RMP Rule (the NPRM)
The major provisions of this proposed rule include several changes to the accident prevention program requirements, emergency response requirements, and public availability of chemical hazard information.  Accident Prevention Program Revisions This action proposes three changes to the accident prevention program requirements. … HomeRead More »
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OMB approves EPA's NPRM on the Risk Management Plan revisions (Modernization of the Accidental Release Prevention Regulations Under Clean Air Act)
This week (2/24/16) we saw the Office of Management and Budget approve EPA’s Notice of Public Rule Making (NPRM) in their attempt to revise their Risk Management Plan rule.  Several weeks ago I posted some of the revisions that EPA is considering and it is hard not to argue for all of their proposed revisions – maybe some of the details can be debated – but the elements they...
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OSHA PSM citations @ plastics resin manufacturer (Formaldehyde & $82K)
Another OSHA PSM citation with some interesting citations. In this one, the company: was using Global FM Engineering Data Sheets as their RAGAGEP(s) for Rupture Disk sizing and Fire Protection, but failed to list these data sheets in their PSI as officially adopted RAGAGEPs. had multiple pieces of equipment on the system that were not tagged, marked or labeled with information to identify equipment...
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FM Global offers FREE GUIDANCE on implementing a "car seal" program
As I have said before, I am a huge fan of Global FM’s Data Sheets, as these FREE data sheets provide EXCELLENT information for businesses who may not have the funds or the ability to use other codes.  And today I got a notice that FM revised their data sheet 7-49, Emergency Venting of Vessels and this revision centers around doing maintenance when we have Installations with...
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The power of a vacuum (Videos w/ Railcar and Tank Truck)
What happens when a vacuum of 23″ of Hg (11.2965 psi) is pulled on a “damaged” Railcar.  This means that there is ~14.7 psi outside the Railcar pushing inward against only 11.29 psi inside the Railcar.  The effect is an amazing force with a very dramatic outcome!   Video in REAL-TIME… … HomeRead More »
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Understanding 1910.145, Specifications for accident prevention signs and tags
Most safety professionals know there is an actual rationale as to when use DANGER, CAUTION, and WARNING signs and how these signs are color-coded; however, there are a lot facilities who may not have a safety professional who can offer this guidance as to when to use signs, how to use them and which one to use for the specific need. Hence, OSHA has a standard that provides us with some VERY SPECIFIC...
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2016 Photo of the Week #8 (E-Stop Guarding)
You wondered what I meant when I said “E-Stop Guarding”, now you see what I meant.  The rationale was the E-stop was too easy to hit so they decided they needed to guard it. 
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2016 Video of the Week #8 (Why there are TRAINED PROFESSIONAL Tree Trimmers - USE THEM!)
 
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A look into OSHA's battles with Congress
I absolutely hate when politics enter into safety, but it is an unfortunate fact that OSHA has to deal with on an on-going basis.  However, like all politics these days, it is just getting ridiculous in what is being expected of OSHA from Congress, that group who can not seem to keep their own chambers in order, but seem to be “safety professionals” who can now manage risks!  I...
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OSHA requesting permission to inspect "small businesses" who have PSM covered processes
You may be asking, what the heck is this all about… you mean OSHA is prohibited from inspecting “small businesses who have PSM covered processes” – YES, in some NAICS’s OSHA has been prohibited from doing PSM inspections when the small businesses are within an industry that has lower than national average injury rates.  Now I am sure you are asking, what the...
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What is Conservative Decision-Making?
Admiral Hyman George Rickover (1900-1986) served more than 60 years of active military duty in the U.S. Navy – longer than anyone in our history. He is known as the Father of the Nuclear Navy. For 34 years, he led the organization that developed the pressurized water reactor technology that propels our nuclear Navy and provides about 14 percent of U.S. electricity (boiling water reactors provide...
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Did a terrorist group and anhydrous ammonia just validate DHS's CFATS?
Today has been very interesting, as I have taken several phone calls from security contacts wanting to learn more about Anhydrous Ammonia (NH3) and terrorist attacks, such as suicide car bombs or small missile attacks on pressure vessels holding NH3.  I am not aware of any security alerts issued by US authorities as of this afternoon, but I do know there is some minor curiosity by some in our...
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