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Author Archives: Brian Chapin
Does your Emergency Action Plan provide for your employees in the event of a plant evacuation?
A northern Kentucky food processing plant experienced an ammonia leak that forced the evacuation of about 160 workers. The employees sat in groups on the lawn outside the building waiting to get belongings like car keys for nearly 11 hours. … Continue reading
Posted in Community Involvement, Incidents
Tagged Emergency Action Plan
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First, Do no Harm!
The OSHA Law Blog has a nice post up called “Best Practices? Or Safety Run Amuck” about the unintended consequences that can occur when people rationalize their opinions as “Best Practice” without bothering to consult with the workers who are expected to … Continue reading
Posted in General Information, System Optimization
Tagged Employee Involvement, Humor, SOP
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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
Posted in Compliance, General Information, NEP
Tagged Fines, OSHA, PSM
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Avoiding training requirements by hiring Contractors? Think again…
I am fortunate to have the opportunity to see a great many different ways to tackle PSM compliance as I audit PSM programs around the country. One thing that surprises me very often is how many people think that they … Continue reading
Posted in Compliance, Contractors, Operator Training, Training
Tagged Contractors, Operator Training, OSHA, PSM
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A few links I wanted to share…
First up, S.K. Energy Consulting: There are some simple to understand articles on Floating Head Pressure and Optimizing Defrost. Check out the articles archives which contain almost 80 newsletters going back several years. Very informational site that I am surprised I … Continue reading
Posted in Compliance, General Information, Standardization, System Optimization
Tagged Efficiency, EPA, OSHA, PSM, RMP, Standardization
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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
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
Posted in Compliance, Tier II
Tagged EPA, Tier II
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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
Posted in Compliance, LOTO, Operator Training
Tagged Fines, LOTO, Operator Training, OSHA
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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
Posted in Compliance, General Information, Good Engineering Practices
Tagged Fines, General Duty, OSHA
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Pressure Relief Valves – The Five Year Replacement Interval
There has been a lot of discussion recently about the five year inspection interval for Pressure Relief valves. I believe that a lot of this discussion comes from this quote out of the National Emphasis Program for Refineries CPL 03-00-010: … Continue reading
Posted in Compliance, Good Engineering Practices, Mechanical Integrity, NEP
Tagged Mechanical Integrity, OSHA, PSM, RAGAGEP
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