Monthly Archives: August 2013

OSHA to revise Palmer guidance on Hydrostatic Trapping

OSHA and the IIAR have not seen eye to eye on the issue of Hydrostatic trapping since 2006 when OSHA issued the Palmer interpretation letter which said the following: If a liquid expansion hazard exists and the only safeguard to protect … Continue reading

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OSHA to focus on difficult inspections (like PSM) in 2014

Taken from the FY 2014 CONGRESSIONAL BUDGET JUSTIFICATION of the OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION: With the agency now in its fifth decade, OSHA finds itself at a crossroads concerning how it will direct its enforcement resources. OSHA has always operated … Continue reading

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The three levels of PSM Compliance…

I’ve always taught that there are three levels of PSM compliance. In my travels throughout the Ammonia Refrigeration Community I’ve seen facilities at every level. I’ve also found that you can fairly quickly figure out what their situation is by … Continue reading

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Did you get a DHS – CFATS/CSAT Top Screen letter?

A lot of people got a letter recently from the Department of Homeland Security telling them that they have to file a CFATS Top-Screen. Unfortunately, some of you got this in error, but for those of you who actually still … Continue reading

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What does OSHA think is the biggest concern in ammonia refrigeration components?

I read a disturbing amount of OSHA documents through FOIA requests for research. About 99% of the stuff I read is pretty useless or already known to me from previous reading, but occasionally you come across something that wasn’t redacted … Continue reading

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Interesting Times

A wise man once said that it was a curse if someone said to you: “May you live in interesting times.” EXECUTIVE ORDER – – – – – – – IMPROVING CHEMICAL FACILITY SAFETY AND SECURITY By the authority vested … Continue reading

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