I have been seeing a lot of RMP citations for failure to UPDATE the facility’s RMP every five (5) years.  By far the number one issue this year based on the ESAs I have been trending.  But one question comes to mind… RMP differs in PSM in a couple of ways, one way being that RMP requires the facility to have a documented “management system to oversee the implementation of...

In the past couple of months OSHA has been rescinding LOIs and issuing new LOIs on PSM Retail Exemption and the 1% rule and at the top of these LOIs (posted online) is a “blanket statement” from OSHA that I find sort of humorous and sad at the same time… “OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and...

In Part 1 of this series I established how this material is a Category 1 Flammable Gas based on both the manufacturer’s SDS and OSHA’s Hazardous Communications Standard Appendix B.  In this article I wish to address how an HFO-1234yf storage tank, which is an ASME pressure vessel, should be labeled, versus how some have been found labeled.  This article will apply to BOTH NFPA...

All year I have received dozens of phone calls and e-mails from friends and colleagues in the automotive industry regarding this new refrigerant for A/C units inside 2016 model vehicles.  Over the next couple of months, I will be posting a series of articles about this new refrigerant and the impact it is having on the automotive industry.  This first article is to clearly establish this...

OSHA has releases their REVISED Training Requirements in OSHA Standards (OSHA 2254-07R 2015)OSHA 2254-07R 2015).  This publication provides a general overview of a variety of standards-related topics. This publication does NOT alter or determine compliance responsibilities which are set forth in OSHA standards, and the Occupational Safety and Health Act.  Moreover, because interpretations...

    Over 12,500 exclusive unsafe acts/conditions and accident/injuries photos and over 1,100 ppt’s & doc’s from more than 2,797 contributors! 2015 Fatality Tracker Electrical 29 (2014 =55) (2013 = 32) (2012 = 68) Forklift/Aerial 29 (2014 = 60) (2013=62) (2012 = 52) Mining* 19 (2014 = 401) (2013=87*) (2012 = 92*) *ONLY developed nations and legal mines Explosions 117 (2014...

 

UPDATED on 9/19/2015 @ 12:25 pm – As I sit here in my truck eating lunch, I thought I would update this posting after having a very nice and interesting phone call with some of the nice and very helpful folks @ OSHA.  Please see the bottom of this post for more info for those of you in General Industry as to how the new CONSTRUCTION CONFINED SPACE standard will indeed impact us. On May 4,...

CLICK HERE for more info on this accident and more pictures.  

CLICK HERE to see the letter

The respondent produces, processes, stores, and/or handles extremely hazardous substances, including hydrochloric acid (36%), due to its toxic and corrosive characteristics and propensity to volatilize in ambient air.  On July 25, 2014, there was a release of hydrochloric acid (36%) at the Facility.  An operator while on his normal rounds gauging the Boiler I house Sump, noticed an abnormal...

Everyone once in a while we come across purged and pressurized enclosures during our PSM/RMP audits involving processes that contain/process flammable liquids or gases.  These purged and pressurized enclosures are used in lieu of using enclosures that are either intrinsically safe or explosion proof.  But this method of protecting the process from ignition sources is NOT as simple as some...