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February 27, 2015
Not a trick question but boy do we get “the look” when we ask the question just as it is written in 68.79 and .119(o). What do OSHA and EPA mean by certifying an audit? Who does this certification? Is this a formal exercise of certifying? Why did OSHA/EPA use this term in the standard? Here is my take…
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February 26, 2015
Recently OSHA.gov has been experiencing some serious issues and although it appears to have gotten almost back to normal, sometimes access to standards is lost. And if you’re like me and do a lot of work in locations where there is no internet connection and you need the standards for a project, here is a FREE and simple way to have ALL of 1910, 1926, Part 68, etc. at your disposal 100%...
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February 25, 2015
A lot is going on with HAZCOM this year and the biggest activity is the conversion from the old MSDSs to the new 16 section format for the SDSs. OSHA recently issued a LOI to clarify the the compliance date… Question: When is an employer required to replace their MSDS collection with revised SDSs in order to be in compliance with HCS 2012? Would OSHA take enforcement action against employers...
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February 25, 2015
I recently participated in a PHA for a large flammable liquids process and during the “facility siting” portion of the PHA we took a detailed tour of the process. During which, several significant “impact” hazards were identified. Of course, the long-time engineering manager (40 plus years of fine service at the facility) quickly went to the “it has been that way...
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February 25, 2015
Over 12,000 exclusive unsafe acts/conditions and accident/injuries photos and over 1,100 ppt’s & doc’s from more than 2,782 contributors! 2015 Fatality Tracker Electrical 9 (2014 =55) (2013 = 32) (2012 = 68) Forklift/Aerial 5 (2014 = 60) (2013=62) (2012 = 52) Mining* 8 (2014 = 401) (2013=87*) (2012 = 92*) *ONLY developed nations and legal mines Explosions 68 (2014 = 157) (2013=194)...
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February 22, 2015
(A) Section 1301 General (1) 1301.1 Scope. The equipment, processes and operations involving dust explosion hazards shall comply with the provisions of this rule. (2) 1301.2 Permits. Permits shall be required for combustible dust-producing operations as set forth in rule 1301:7-7-01 of the Administrative Code. (B) Section 1302 Definitions (1) 1302.1 Definition. The following word and term shall, for...
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February 22, 2015
OSHA issued a memorandum to its Regional Administrators and State Designees on 12/242014. The memorandum provides Area Offices with guidance on when an on-site inspection is warranted. OSHA has divided injury and illness reports into three categories. OSHA will inspect facilities that report an injury or illness that falls into one of the first two categories and will issue a RRI...
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February 22, 2015
A crew was conducting well kill operations on a sweet oil well. A worker was monitoring the return flow to the service rig trough from on top of the rig tank. When the returns became gassier, the return flow was opened to the degasser section of the rig tank and the trough flow was pinched in slightly. The rig manager proceeded to the top of the rig tank stairs where his personal gas monitor immediately...
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February 21, 2015
This Alert is intended to inform the industry that companies must take responsibility to prevent accidental releases of dangerous chemicals like anhydrous ammonia through compliance with CAA’s Chemical Accident Prevention Program. Evidence gathered by the U.S. Environmental Protection Agency (EPA) indicates that some refrigeration facilities may be failing to properly manage hazardous...
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February 21, 2015
Over the years I have posted several articles about hazardous materials being unloaded to the wrong tank. And it seems that each time I do I get several e-mails stating how rare these events are and that I am being an alarmist. So I thought I would post a section of a PHMSA Investigation Report from an incident where Sulfuric Acid was unloaded into a tank with Hydrochloric Acid. The...
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