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Your Emergency Response Plan Section (q)(2)(i) - Pre-emergency Planning and Coordination
We see a lot of great efforts on emergency response plans, but so many times, folks do not know the details OSHA will be looking for. Here are the required sections/information for your ERP and the details required. (q)(2)(i) Pre-emergency Planning and Coordination  … HomeRead More »
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Emergency Response & PSM Tip
Most of the facilities we work at have a mechanical integrity program for the process equipment. Most have a Work Order system for their preventative maintenance program. This system kicks out a work order for the PM(s) due. Most facilities track the closure rates of the PM W.O.’s. My tip… Add ALL of your emergency response equipment to this system. Items such as: sprinkler annual flow...
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Better be thinking MOC before you do RBI
That is PSM lingo for…when you are utilizing Risk Based Inspection (RBI) protocols and you wish to extend the inspection or PM frequencies on a piece of covered equipment, this is without a doubt a change that REQUIRES an MOC. … HomeRead More »
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Mechanical integrity management of bulk storage tanks
Following the Buncefield incident the importance of preventing loss of containment from bulk storage tanks has come to the fore. A significant factor in ensuring contained fluids are not accidentally released is the continuing mechanical integrity of the tank structure. http://www.hse.gov.uk/research/rrhtm/rr760.htm
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Trick Question or legit question for PSM Compliance? Contractor Evaluations and PRCS Rescue Evaluations
OK, PSM requires us to evaluate our “contractors” who will be working on, in or adjacent to a covered process. OSHA’s Permit Required Confined Space Standard also comes into play during a PSM audit (see .119(f)(4)). Under the PRCS std. OSHA requires us to “evaluate” our rescue services (.146(k)(1)(i)-(ii)) using something similar to Appendix F from .146. Since I have yet...
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What are "Temporary Operations" in regards to PSM Operating Procedures 1910.119(f)(1)(i)(C)
We always get the answer…”We do not have any temporary operations,” so that does not apply to us. A good auditor will educate the site personnel by taking them out to the field and finding a bypass around a control device. Then, we will ask for the “procedure” that is used when the bypass is open and the control device is “temporarily” out of service. If you...
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The difference between a MOC and PSSR
Often we see facilities viewing MOC and PSSR’s management systems as DUPLICATIVE efforts. There is a distinct difference between these two PSM/RMP requirements. Basically, this is how it was so explained to me by Russ Evanston, one of the founding fathers of PSM. … HomeRead More »
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Staffing and Management of Change
OSHA and EPA are now citing for not doing MOCs on personnel changes!  The debate rages on for those living in the PSM/RMP world. Just this week, a client called me to help them with an audit finding they received in a third-party audit. The auditor wrote the finding that they were not considering personnel changes in their MOC program. I too often write a similar finding when I come across situations...
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Nitrogen an ignition source...yeah right Mr. Safety Man!
Well I told you last week that I would scare the !@#$ out of a lot of you, so here it goes.  Nitrogen can be your ignition source if it is NOT applied and used properly. … HomeRead More »
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Safety Communications...When is it too much?
I have always said that 90% of establishing a safety culture is communication of safety ideas and information.  Safety is competing for the minds of all workers to THINK about SAFETY in all that they do.  We are competing with Quality, Production, Costs Control, Family, etc. in the thoughts of our workers.  A lot of marketing companies have made a ton of $ on selling posters and banners...
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Isolation for Reclassification of Permit-Required Confined Spaces
There is a lot of confusion on reclassifying Permit-Required Confined Spaces to Non-Permit Spaces, which is allowed on spaces with NO KNOWN or POTENTIAL hazardous atmospheres. 1910.146(c)(7) covers this practice. The key DIFFERENCE between “reclassifying” a space using section (c)(7) and using “alternative entry methods,” which is covered under section (c)(5) is ELIMINATION...
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23 incidents & 1 update (3/23/11)
Many THANKS to my NEW & RENEWING Corporate Partners in Safety! since 2007 since 2011 since 2009 since 2/11 2011 Fatality Tracker Electrical 6 (2010 = 90) (2009 = 100) Forklift/Manlift Mobile Equipment  27 (2010 = 110) (2009=88) Mining 43 (2010 = 480) (2009...
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