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Tag Archives: OSHA
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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OSHA replaces the ChemNEP inspection protocol
Since 2011, Ammonia Refrigeration facilities with 10,000lbs. or more of Anhydrous Ammonia have been subject to ChemNEP inspections under CPL 03-00-14. OSHA has replaced this program with a new program that makes some changes: Merges the Petroleum and Chemical NEPs … Continue reading
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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Who is Certified / Qualified to Train Process Operators?
Variations of this question are a favorite of OSHA/EPA inspectors and generally the question is infuriating. It reminds me of the stories of medieval monks arguing over how many angels can dance on the head of a pin – it’s … Continue reading
Posted in Compliance, EPA, Operator Training, OSHA
Tagged EPA, Operator Training, OSHA
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Misunderstanding MOC
Recently a valve manufacturer that I respect posted a LinkedIn advertisement for one of their new relief valves. I love new technology so I was really interested in it but noticed something they posted in the graphic: “No PSM Changes … Continue reading
Posted in Compliance, Good Engineering Practices, Management of Change
Tagged EPA, Management of Change, OSHA
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A little memo with some very big implications
Memo of Understanding between the DOL and DOJ: The U.S. Department of Labor (DOL) and the U.S. Department of Justice (DOJ), recognizing the importance of ensuring the health and safety of America’s workforce, enter into this memorandum of understanding … Continue reading
Posted in Community Involvement, Compliance, OSHA
Tagged OSHA
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OSHA fines to rise 80%?
OSHA Defense Report says that the “Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015,” gives OSHA the green light to increase penalty amounts to catch up with cost of living adjustments since the last time OSHA’s civil penalties … Continue reading
OSHA Memo on RAGAGEP
Link to OSHA publication – Highlights (underline) are mine. Note that they reference the CCPS again. The really good stuff is at the bottom in the notes to the inspectors. MEMORANDUM FOR: REGIONAL ADMINISTRATORS AND STATE PLAN DESIGNEES THROUGH: DOROTHY DOUGHERTY … Continue reading
Region 7 Ammonia Safety Day
If you are within a couple hundred miles of Kansas City, Kansas it’s worth attending the 7th annual Region 7 Ammonia Safety Day which is held at the Kansas City Community College on May 28th, 2014. More information including the schedule and enrollment … Continue reading
Posted in Community Involvement, Compliance, CSB, EPA, Operator Training, OSHA
Tagged CSB, EPA, Operator Training, OSHA, PSM, RMP
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Relief Systems – Understanding Design and Design Basis
In compliance audits all over the country, we’re finding that the requirements for documenting the relief systems are not being met in many PSM programs. How bad is the situation? About 1/3rd of the relief documentation we see shows that … Continue reading
Posted in Compliance, Good Engineering Practices
Tagged EPA, OSHA, RAGAGEP
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