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Tag Archives: PSM
Paying for PSM, California Style
The state of California is having some trouble funding their oversight of their state PSM rule: CalARP. Don’t worry though, they have a solution… The Department of Industrial Relations, Division of Occupational Safety and Health (DOSH) is proposing to adopt emergency … Continue reading
Posted in General Information, Oddities
Tagged Government, PSM, RMP
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How do I deal with recommendations to my program?
You should frequently get recommendations for improving your PSM program through the PSM elements of Employee Participation, Process Hazard Analysis, Incident Investigations, Mechanical Integrity audits, Compliance Audits. Often, these recommendations are worthwhile improvements to your system that are worthy of … Continue reading
Posted in Compliance, Incidents, OSHA
Tagged Employee Involvement, Incidents, Mechanical Integrity, OSHA, PSM, RMP
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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
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OSHA to revise Palmer guidance on Hydrostatic Trapping
OSHA and the IIAR have not seen eye to eye on the issue of Hydrostatic trapping since 2006 when OSHA issued the Palmer interpretation letter which said the following: If a liquid expansion hazard exists and the only safeguard to protect … Continue reading
Posted in Compliance, Good Engineering Practices, NEP
Tagged OSHA, PSM, RAGAGEP, Standardization
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OSHA to focus on difficult inspections (like PSM) in 2014
Taken from the FY 2014 CONGRESSIONAL BUDGET JUSTIFICATION of the OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION: With the agency now in its fifth decade, OSHA finds itself at a crossroads concerning how it will direct its enforcement resources. OSHA has always operated … Continue reading
The three levels of PSM Compliance…
I’ve always taught that there are three levels of PSM compliance. In my travels throughout the Ammonia Refrigeration Community I’ve seen facilities at every level. I’ve also found that you can fairly quickly figure out what their situation is by … Continue reading
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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So, you need a PSM coordinator…
The Situation: Several times a month I get a call from a recruiter or a facility that desperately needs to fill a PSM coordinator position. They quickly learn something that many people in our industry are unaware of – quality … Continue reading
Posted in Compliance, General Information, Training
Tagged Employee Involvement, General, Operator Training, PSM, RMP
1 Comment
The real cost of an OSHA/EPA fine isn’t the check you write
Sure, it’s painful to write a check to pay fines, but if you think that fine is the cost of OSHA/EPA non-compliance, you’re in for a rude awakening. The real cost of a fine from OSHA or the EPA isn’t … Continue reading
Posted in Community Involvement, Compliance, EPA, Inspections, OSHA
Tagged EPA, Fines, OSHA, PSM, RMP
Comments Off on The real cost of an OSHA/EPA fine isn’t the check you write
Maximum Intended Inventory (1910.119(d)(2)(i)(C))
Lately we’ve been seeing quite a few misunderstandings of the inventory calculations required by a PSM program so I thought I would try and explain it as simply as I can. Both the EPA’s RMP and OSHA’s PSM require you … Continue reading
Posted in Compliance, EPA, Good Engineering Practices, NEP
Tagged EPA, OSHA, PSM, RAGAGEP, RMP
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