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August 14, 2017
This week we learned of a lawsuit in KS regarding the location of a proposed (actually permitted) cold storage facility. Landowners near the facility have filed suit asking a judge to reverse the county commission’s approval of the 411,000 square feet cold-storage facility near their homes. Neighbors say the plan doesn’t provide the right setbacks or enough screening from the plant....
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August 14, 2017
This posting includes some very interesting citations issued by EPA (not OSHA). For example, EPA took issue with using “pink ribbons” on valves being used in an energy isolation for contractors installing a piece of equipment – rather than LOTO locks or tags! This “ribbon” idea is still fairly prevalent in the refrigeration industry still today, as evident...
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August 7, 2017
Just an FYI for those of you who have RMP covered processes in the state of NC. Not much different than what we see with federal inspection data, but there are some interesting differences none the less…
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August 6, 2017
One of the most misunderstood operating procedures in OSHA’s PSM and EPA’s RMP standards is the “Initial Start-Up procedure”. OSHA, nor EPA has offered a lot of written guidance, on this requirement and this has led to a lot of confusion as to why it is called out and how this SOP differs from a “Normal Start-Up” SOP. But anyone who has a PSM (or maybe an RMP) process that handles a non-conductive...
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August 4, 2017
EPA found that Respondent, a fertilizer business, had violated regulations implementing Section 112(r) of the Act at 40 C.F.R. Part 68 by failing to comply with the regulations as noted on the enclosed “Risk Management Plan Inspection Findings and Alleged Violations Summary”. In consideration of Respondent’s size of business, its full compliance history, its good-faith effort to comply,...
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August 3, 2017
Respondent owns and operates a meat production and packaging facility. 20. Information gathered during the EPA inspection revealed that Respondent had greater than 10,000 pounds of anhydrous ammonia in a process at its facility. On or a bout October 20-21, 2015, EPA conducted an inspection of Respondent’s Facility to determine compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68....
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August 1, 2017
Many thanks to my friends at EPA (and OSHA) for sharing this EPA RMP Checklist specific to Ammonia Refrigeration Processes. Here are the “highlights” specific to NH3 processes. It should be noted that this RMP Checklist specific to Ammonia Refrigeration Processes was developed in conjunction with the International Institute of Ammonia Refrigeration (IIAR) and...
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