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Category Archives: Inspections
Why OSHA’s Statute of Limitations doesn’t really matter in PSM/RMP
You may have recently heard a headline that OSHA is losing their right to cite you for something that happened more than six months ago. I’ve heard a disturbing amount of people tell me that this means that many PSM issues … Continue reading
Posted in Compliance, Inspections, OSHA
Tagged EPA, Fines, OSHA, PSM, RMP
Comments Off on Why OSHA’s Statute of Limitations doesn’t really matter in PSM/RMP
What questions should I expect during a ChemNEP inspection?
A friend in the industry recently went through an OSHA ChemNEP inspection on their NH3 Refrigeration System. Over the years, I’ve had the pleasure of working with many of their team members and have audited several of their facilities. They … Continue reading
Posted in Compliance, General Information, Inspections, Mechanical Integrity, NEP, Operator Training, OSHA, SOP Development, Training
Tagged Fines, Lessons Learned, Mechanical Integrity, NEP, Operator Training, OSHA, PSM, RAGAGEP, Standardization
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Pencil-Whipping can Kill
What is it? Pencil-whipping is when you complete a form, record, or document without having performed the implied work or without supporting data or evidence. Here are some common examples in NH3 refrigeration: Completing “word orders” without conducting the work … Continue reading
Posted in Compliance, Culture, General Information, Incidents, Inspections, Mechanical Integrity, Operator Training, System Optimization
Tagged General, Incidents, Lessons Learned, Mechanical Integrity, Operator Training
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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
Posted in Compliance, Contractors, Inspections, Mechanical Integrity, Operator Training, OSHA
Tagged Contractors, Fines, Mechanical Integrity, PSM
Comments Off on Appeals Court upholds Contractor PSM Citations
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
Posted in Compliance, General Information, Inspections, NEP, OSHA
Tagged Fines, NEP, OSHA, PSM
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EPA goes after a cold storage, the real estate agent AND the customer leasing the space!
Complainant issued a Compliance Order to Respondent, and also to Quirch Foods Caribbean, Corp., and Caparra Realty Associates, LLC ( “the Order”) pursuant to Section 1 13 of the Act regarding the Facility. The Order required these parties to perform … Continue reading
Posted in Compliance, EPA, General Information, Inspections
Tagged EPA, Fines, RMP
Comments Off on EPA goes after a cold storage, the real estate agent AND the customer leasing the space!
OSHA is going to have a field day in 2016
The IIAR released two new standards today which you can download (if you are a member) or purchase from their website: IIAR5 – Start-up and Commissioning of Closed Circuit Ammonia Refrigeration Systems IIAR7 – Developing Operating Procedures for Closed-Circuit Ammonia Mechanical Refrigerating … Continue reading
Posted in Compliance, Inspections, NEP, SOP Development, Standardization
Tagged NEP, OSHA, PSM, RAGAGEP
Comments Off on OSHA is going to have a field day in 2016
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
Posted in Compliance, Inspections, Mechanical Integrity, OSHA
Tagged Fines, Mechanical Integrity, OSHA, PSM
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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
Posted in Community Involvement, Compliance, EPA, Inspections, NEP
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Hansen Relief Valve Recall
If you use Hansen relief valves, this bulletin might be of use to you: . Hansen recently discovered that certain pressure relief valves sold to our customers for industrial use from February 16, 2011 to April 4, 2013 are more … Continue reading
Posted in General Information, Inspections, Mechanical Integrity
Tagged Mechanical Integrity
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