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Category Archives: Compliance
Garden City Ammonia Program PodCast
I recently had a long conversation with Craig Ward of Garden City Ammonia Program. He turned it into an episode for their GCAP Cool Cast. You can listen to the entire conversation here. As always – feedback is welcome.
Posted in Community Involvement, Compliance, General Information, Good Engineering Practices, Operator Training, Standardization
Tagged Biography, Efficiency, EPA, General, Incidents, Mechanical Integrity, OSHA, PSM, RAGAGEP, RMP, Standardization
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RAGAGEP: Just what is it?
RAGAGEP stands for Recognized and Generally Accepted Good Engineering Practice. OSHA: OSHA 29 CFR 1910.119 (D)(3)(ii): “The employer shall document that equipment complies with recognized and generally accepted good engineering practices.” EPA: EPA 40 CFR 68.73 (d)(2): “Inspection and testing … Continue reading
Posted in Compliance, General Information, Good Engineering Practices
Tagged EPA, OSHA, PSM, RAGAGEP, RMP
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Fatal spill brings $91,000 fine
South Carolina regulators have fined a Pennsylvania company $91,000 for a string of emergency preparedness failures they say occurred before a fatal chemical leak near its Swansea plant last year. The Department of Health and Environmental Control says the wrong … Continue reading
Posted in Community Involvement, Compliance, Incidents
Tagged Fines, Incidents, Mechanical Integrity, OSHA
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Unattended Operation? Better get Ammonia Detection!
Certainly your ammonia technician will pick up any minor leaks during a regularly scheduled walk-through of the facility. But what if that leak starts at 6pm Friday evening and everyone is gone for the weekend? You had better have some … Continue reading
Posted in Community Involvement, Compliance, Good Engineering Practices
Tagged Fines, OSHA, PSM
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National Emphasis Program targeting Chemicals to Continue
“OSHA’s scrutiny of the refinery industry and of chemical facilities covered by the Process Safety Management standard will increase, Jordan Barab, deputy assistant secretary of OSHA said in an Oct. 27 speech at the 2010 Mary Kay O’Connor Process Safety Center … Continue reading
Posted in Compliance, General Information
Tagged OSHA, PSM
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Another six figure Ammonia Refrigeration Process Safety Management fine
From the OSHA press release: BRAINTREE, Mass. – The U.S. Department of Labor’s Occupational Safety and Health Administration has cited American Seafoods International LLC for 15 alleged willful and serious violations of safety and health standards at its New Bedford, … Continue reading
Posted in Compliance
Tagged Fines, OSHA, PSM
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OSHA PSM National Emphasis Program Extended
Last year our good friends at OSHA finally started moving their PSM inspectors away from the oil refineries. A National Emphasis Plan was created to audit PSM. The NEP is targeted at Ammonia and Chlorine users – 32411 NAICS code … Continue reading
Actual OSHA Citations
Here’s a summary of two recent collections of proposed fines from OSHA. I’m not in any way affiliated with either of these facilities; I was just fortunate enough to get copies of the citations. There are plenty of things in … Continue reading
EPA settles with Pacific Seafood Group
EPA extracted a $35,000 penalty for not complying with the Emergency Planning and Community Right to Know Act. In the agreement, EPA alleges that Pacific Seafood failed to immediately notify emergency response entities after the ammonia release occurred and they failed … Continue reading
Posted in Compliance
Tagged CERCLA, EPA, Fines
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OSHA vs. EPA
If you are covered under OSHA’s PSM regulation you know that you are covered under the EPA’s RMP regulation as well. I understand why most people focus on the PSM regulations – they are used to dealing with OSHA regulations … Continue reading