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Making the case my PSM/RMP covered process complies with RAGAGEPs (Vessels)
This is a follow up to my July 2013 article “Making the case my PSM/RMP covered process complies with RAGAGEPs (Piping)”.  With OSHA’s recent memo on “RAGAGEP in Process Safety Management Enforcement” I have received renewed request to explain how a facility can demonstrate their vessels/tanks comply with RAGAGEP(s).  Here it goes: … HomeRead More...
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Safety Alert - fatality due to hydrotest burst
Safety alert fatality due to hydrotest burst overpressured pipe from Alan Bassett  
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Does the “voluntary use” of a "filtering facepieces" (dust masks) require the use Appendix D?
Are you providing a copy of 1910.134 Appednix D to each employee who wears a filtering facepieces (dust masks) on a “voluntary basis”? Are you controlling these filtering facepieces (dust masks) so that ONLY employees who have been provided with a copy of Appendix D have access to these filtering facepieces (dust masks)?  For the past 15 or so years I, and I know of many other safety...
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Looking for a FREE Safety Culture Survey?
As part of their Industrial Safety Ordinance Contra Costa County, CA developed a VERY NICE safety culture survey.  It is a requirement for CalARP facilities, but just a GREAT RESOURCE for the rest of us.  Check it out Attachment E: Safety Culture Assessment (PDF).  You may have some work to do to get it in a manageable format, but the content is WORLD-CLASS and it is FREE! Industrial...
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EPA RMP vs. CalARP (CA Accidental Release Program)
When it comes to EPA’s Risk Management Plan rule, the state of California made significant modifications to the RMP rule.  Basically, California replaced the Risk Management and Prevention Program with the California Accidental Release Prevention (CalARP) Program on January 1, 1997. The CalARP Program is very similar to the EPA’s Risk Management Program with the following differences:...
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Hazardous Materials: Flame Arrestors (USFA)
  CLICK HERE for the pdf
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OSHA's presentation on RAGAGEP Enforcement from 2015 ASSE
Here is the presentation that Jim Lay, P.E., from OSHA’s Office of Chemical Process Safety & Enforcement Initiatives did last week @ ASSE’s Annual Conference.  He did this presentation the same day OSHA rolled out their new enforcement policies on chemical mixtures and RAGAGEP enforcement.  The presentation covers RAGAGEP Background, Early recognition of RAGAGEP, RAGAGEP in...
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50 incidents & 1 update (6/15/15)
  Many THANKS to my NEW and RENEWING “Partners in Safety“ – See more at: http://www.safteng.net/#sthash.3AXLlGgX.dpuf 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 21 (2014 =55) (2013 = 32) (2012 = 68) Forklift/Aerial...
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OSHA memo Evaluating Hazardous Levels of Accumulation Depth for Combustible Dusts (4/21/15)
April 21, 2015 MEMORANDUM FOR: REGIONAL ADMINISTRATORS THROUGH: DOROTHY DOUGHERTY Deputy Assistant Secretary FROM: THOMAS GALASSI, Director Directorate of Enforcement Programs SUBJECT: Evaluating Hazardous Levels of Accumulation Depth for Combustible Dusts   The purpose of this memorandum is to provide guidance in calculating the levels of dust accumulations that may be allowed at...
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How could OSHA’s move to EPA’s “1% rule” for mixtures change at facilities handling OSHA PSM HHC mixtures?
PLEASE NOTE the LOI in which OSHA adopted EPA’s 1% rule was thrown out by the courts so I am NOT 100% sure OSHA can use the 1% rule from EPA in their evaluations of what is a covered process/HHC. Last week OSHA changed their position in how they will handle “mixtures” of those chemicals listed in 1910.119 Appendix A WITHOUT a concentration percentage listed.  OSHA rescinded...
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What the heck is "partial pressure" and how do I calculate it for my PSM/RMP mixture?
With OSHA’s change last week in how PSM applies to “mixtures” of HHCs I have received a number of questions about “partial pressure” and what impact it can have on whether my process is covered or not?  EPA has been using “partial pressure” of 10 mm Hg for their mixture applicability rule since 1999, but there are a lot of PSM processes that are not covered...
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2015 Video of the Week #24 (Electrical Safety @ a safety convention)
I shot this video just before my safety training session at a safety convention this summer.  When I asked for it to be fixed, the venue manager and workers were confused because the projector had power.  When I tried to explain the issue they all of a sudden had trouble with the english language.  If we can not expect mere compliance with the most basic of electrical safety while working...
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