Category Archives: OSHA

Appeals Court upholds Contractor PSM Citations

A maintenance contractor that provides skilled labor to perform skilled labor, electrical and mechanical work was cited by OSHA for violations of the PSM standard after their employee was injured by a chemical release. OSHA threw the book at them … Continue reading

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OSHA increases fine amounts by 78%!

In November 2015, Congress enacted legislation requiring federal agencies to adjust their civil penalties to account for inflation. The Department of Labor is adjusting penalties for its agencies, including the Occupational Safety and Health Administration (OSHA). OSHA’s maximum penalties, which … Continue reading

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Who is Certified / Qualified to Train Process Operators?

Variations of this question are a favorite of OSHA/EPA inspectors and generally the question is infuriating. It reminds me of the stories of medieval monks arguing over how many angels can dance on the head of a pin – it’s … Continue reading

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A little memo with some very big implications

  Memo of Understanding between the DOL and DOJ: The U.S. Department of Labor (DOL) and the U.S. Department of Justice (DOJ), recognizing the importance of ensuring the health and safety of America’s workforce, enter into this memorandum of understanding … Continue reading

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OSHA fines to rise 80%?

OSHA Defense Report says that the  “Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015,” gives OSHA the green light to increase penalty amounts to catch up with cost of living adjustments since the last time OSHA’s civil penalties … Continue reading

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OSHA Memo on RAGAGEP

Link to OSHA publication – Highlights (underline) are mine. Note that they reference the CCPS again. The really good stuff is at the bottom in the notes to the inspectors.   MEMORANDUM FOR: REGIONAL ADMINISTRATORS AND STATE PLAN DESIGNEES THROUGH: DOROTHY DOUGHERTY … Continue reading

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Region 7 Ammonia Safety Day

If you are within a couple hundred miles of Kansas City, Kansas it’s worth attending the 7th annual Region 7 Ammonia Safety Day which is held at the Kansas City Community College on May 28th, 2014. More information including the schedule and enrollment … Continue reading

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Should you challenge OSHA citations?

Will Kramer has written an excellent article on why you should challenge OSHA citations. Based on an analysis of the more than 57,000 citations listed in OSHA’s public inspection databases in 2012, employers achieved an average penalty reduction of 49% … Continue reading

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H.R.1648 – Protecting America’s Workers Act

Rep. Miller, George [D-CA-11] has introduced legislation to revise the OSHA penalty structure. There are some interesting changes in this legislation: Repeat Violations – Increased from $70,000 to $120,000 Serious Violations – OSHA has requested increase from $7,000 to $12,000. … Continue reading

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How do I deal with recommendations to my program?

You should frequently get recommendations for improving your PSM program through the PSM elements of Employee Participation, Process Hazard Analysis, Incident Investigations, Mechanical Integrity audits, Compliance Audits. Often, these recommendations are worthwhile improvements to your system that are worthy of … Continue reading

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