Tag Archives: Fines

NRC Call – When is it necessary? When is it a good idea?

Most people involved with Ammonia Refrigeration understand that if we have an unintentional release of ammonia in excess of 100 pounds over a 24hr period, we have to report it to the National Response Center (among others) immediately or face … Continue reading

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Do your Emergency Shut-down and Ventilation switches comply with IIAR2-2008b/IIAR5-2013, Appendix B?

IIAR5 was released just recently and a surprising number of people think that it introduces new requirements for emergency switches. The requirements themselves don’t differ from IIAR2-2008b – they are just laid out a little clearer in IIAR5, Appendix B: … 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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Five Year Independent Full Inspection

IIAR Bulletin 110, Section 6.4.4 calls for something called an “Independent Full Inspection”: At least every five years, the annual inspection of the vessels and heat exchangers shall be carried out by a competent person independent of immediate commercial and … Continue reading

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EPA & Tyson agree to settle in a BIG way

The U.S. Environmental Protection Agency (EPA) and the U.S. Department of Justice announced a Clean Air Act (CAA) settlement with Tyson Foods, Inc. and several of its affiliate corporations to address threats of accidental chemical releases after anhydrous ammonia was … Continue reading

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The real cost of an OSHA/EPA fine isn’t the check you write

Sure, it’s painful to write a check to pay fines, but if you think that fine is the cost of OSHA/EPA non-compliance, you’re in for a rude awakening. The real cost of a fine from OSHA or the EPA isn’t … Continue reading

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PSM Citations – A year broken down by Industrial Classification

OSHA has posted a breakdown of PSM citations so you can compare industry groups that have been cited by Federal OSHA during the period October 2010 through September 2011. I plugged this data into Excel and ran some numbers between … Continue reading

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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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