Category Archives: Compliance

Regulatory Compliance

Refresher Training

Many people struggle with Refresher Training. I think this is because the way they train to meet the PSM/RMP requirement is fundamentally flawed: Most places re-train each operator on EVERY SOP they are expected to perform at least every three … Continue reading

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No NH3 Detection – General Duty Citation in store?

Most General Duty citations have nothing to do with Ammonia refrigeration but I’ve started to see a trend recently where processes that are not covered by PSM are being subject to Recognized and Generally Accepted Good Engineering Practices (RAGAGEP). The … Continue reading

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PSM Covered Chemical Facilities National Emphasis Program goes NATIONWIDE!

OSHA promulgated the PSM standard in 1992 in response to a number of catastrophic incidents that occurred worldwide (See Process Safety Management of Highly Hazardous Chemicals, 29 CFR 1910.119).  These incidents spurred broad recognition that releases of highly hazardous chemicals … Continue reading

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Torque Wrenches for Ammonia refrigeration valves

Yes, it really has come to this. Let’s start with a single citation… What equipment could this citation be concerning? Take a look at the compliance officer’s narrative: The officer went on to say in the OSHA 1-B Inspection worksheet: … Continue reading

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OSHA cites Kraft in Madison Wisconsin

MADISON, Wis. – The U.S. Department of Labor’s Occupational Safety and Health Administration has cited Kraft Foods Inc. for 12 serious and one other-than-serious safety violation at a facility of its subsidiary, Oscar Meyer, in Madison. Proposed fines total $75,000. … Continue reading

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Bostik Fines – Following up on Audit Recommendations MATTERS!

BOSTON – The U.S. Department of Labor’s Occupational Safety and Health Administration has cited Bostik Inc. for 50 alleged violations of workplace safety standards following a March 13 explosion at the company’s Middleton plant in which four workers were injured. … Continue reading

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OSHA 2010 Enforcement Summary and Willful Violations

“In FY 2010, OSHA found 96,742 violations of OSHA’s standards and regulations in the nation’s workplaces, a 15.3% increase since FY 2006.  The total number of serious and repeat violations issued increased by 22.1% and 8.1%, respectively, over the past … Continue reading

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The Regulatory Challenge

I came across two recent articles that touch upon the ever-increasing size of the challenge businesses face when it comes to regulation. It’s interesting to see the size of the regulatory apparatus compared to private enterprise: “If the federal government’s … Continue reading

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PSM NEP Podcast

I spent about two hours in the recording studio today with Jeremy Williams of GCAP. You can listen to the first part of our conversation on the NEP at GCAPCoolCast.com I’ve spent the last three weeks at GCAP re-working the … Continue reading

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PSM National Emphasis Program

If you aren’t familiar with the NEP (National Emphasis Program) currently going on in specific regions it would be well worth your time to get up to speed. Even if you have a top-notch program you’ve got a LOT of … Continue reading

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