Monthly Archives: July 2012

Unclear on the concept…

This one starts simply enough: 1910.119(d)(3)(ii) The employer did not document that the equipment in the process complied with recognized and generally accepted good engineering practices. In this case the citation is in regards to an MSA gas monitor that wasn’t … Continue reading

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Revisions to the Tier I and II Emergency and Hazardous Chemical Inventory Forms

The following is an update from EPA’s Superfund, TRI, EPCRA, RMP & Oil Information Center: On July 13, 2012, EPA modified the EPCRA Section 312 Emergency and Hazardous Chemical Inventory Forms (Tier I and Tier II) to add new mandatory … Continue reading

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Violation by Violation – Training at Tribe Mediterranean Foods

It looks like Tribe may be working towards a quick settlement in their recent citations. The citation is a good example of what can happen with Willful citations: Seven employees weren’t trained properly for LO/TO and each was cited as a … Continue reading

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Ammonia citations under the General Duty clause

Most of us in the Ammonia Refrigeration industry are dealing with a PSM covered process, but there are some of us who are not required to implement PSM because we don’t have a threshold quantity. The real worry for those … Continue reading

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