OSHA PSM

Ammonia Refrigeration & PSM Contractor Qualification, Training Edition

Most companies will go to some degree of lengths in selecting “qualified” contractors to include things such as job examples, a list of qualifications, require subscription to the ISN network, etc. Even then, though, sometimes bad apples slip through the cracks if the company needing a “qualified” contractor doesn’t develop a scope or set of […]

OSHA PSM Citations @ Food Processor (NH3 & 131K)

The state of VA has fined a food processor $131,535 for a July 31, 2024 anhydrous ammonia leak that hospitalized 33 people. The leak triggered the evacuation of 287 employees working at the facility. Five of the 33 victims were hospitalized with serious conditions, 17 had serious but non-life-threatening conditions, and 11 had minor symptoms.

Temporary SOP or a Car-Seal or Both?

The arrangement below is very common in processes/systems. This simple yet common arrangement causes havoc in hazard analyses. As the title states, is this arrangement managed with a Temporary SOP, a Car-Seal, or Both? The issue is that the motorized valve is tied to a Hi-Hi level alarm and interlock. When the vessel archives its

Never be too confident of our written SOPs/JSAs

We MUST never be too confident of our written SOPs/JSAs. There is a good reason why “Administrative Controls” are down on the Hierarchy of Controls. When we think our SOPs/Plans are infallible, our workers will show us a thing or two… And when we investigate adverse events and this leads us to “failure to follow

When will the ammonia refrigeration industry finally embrace LOTO? (Part I)

By: Victor Dearman Jr. CIRO, CRST Flagging tape is not LOTO! And never has been. I would bet good money the operating procedure for this compressor has LOTO covered, but those are just documents to look good in a binder sitting on a shelf collecting dust because they are viewed as a necessary evil to

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