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NBIC frequencies
What is the REQUIRED FREQUENCY of my relief valve(s) maintenance
In my last several Process Safety courses, I had several requests for “code requirements” surrounding Relief Valve “maintenance” (e.g., inspection, replacement, and rebuild frequencies).  In general, there is the “at least every five years” interval that is ever so popular, and the vast majority of manufacturers will REQUIRE their RV(s) the be changed/rebuilt/certified...
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1910169
OSHA citations for NOT managing Relief Valves on Air Receivers (1910.169)
Here is another recent citation from OSHA on a standard that gets very little attention, 1910.169 Air ReceiversAir Receivers. 1910.169(b)(3)(iv) All safety valves shall be tested frequently and at regular intervals to determine whether they are in good operating condition.                                   Least...
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1910132c
OSHA uses 1910.132(c) to cite GI workplace for improper use of PFAS
A question that seems to be asked more and more is “do my harnesses and lanyards fall under the same requirements as those used on construction sites?”.  This is another one of the questions that I have no idea where it came from or how the myth that the Personal Fall Arrest System (PFAS) used in a general industry workplace somehow does not have to follow the same principles as that...
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2016 Photo of the Week #9 (Forklift + Scissor Lift)
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Updating your Asbestos Signs before June 1, 2016 to comply with the new GHS HAZCOM (OSHA LOI)
In 2012, OSHA revised the standard, 29 CFR 1910.1200, Hazard Communication (HCS 2012). [Reference, 77 Fed. Reg. 17574 (Mar. 26, 2012)]. This rulemaking also made minor changes to several other OSHA standards related to hazardous chemical communication, such as revising the legend used on the warning sign to a regulated work area specified in OSHA’s standard for general industry, 29 CFR 1910.1001,...
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2016 Video of the Week #9 (Crane, Mini Digger, and Aerial Lift)
 
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Tying your Maximum Intended Inventory back to your material and energy balances
In October 2015 I wrote about justifying our Maximum Intended Inventories (MII) so that we balance business needs with risks associated with large quantities of highly hazardous chemicals on site. Now we have come full circle and now a facility is being asked to define their MII as it relates to their material and energy balances. … HomeRead More »
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67 incidents & 0 updates (2/25/16)
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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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