Tag Archives: Fines

What you need to know about Repeat Citations

First, what is a Repeat Citation? Here’s what OSHA has to say about it in their Field Operations Manual or FOM: An employer may be cited for a repeated violation if that employer has been cited previously for the same … Continue reading

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General Duty vs. PSM/RMP: Is there a benefit to dropping below the 10,000lb threshold?

Several times a year I get a phone call or an email from a client that wants to lower the NH3 inventory below the federal 10,000lb threshold so they are no longer subject to the PSM/RMP rules. It’s a conversation … Continue reading

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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

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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

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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

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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

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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

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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

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$205,000 fine for dumping 40 pounds of ammonia

Kodiak fish processor North Pacific Seafoods pleaded guilty Tuesday in federal court to illegally dumping ammonia into the Kodiak city sewer, while the processor’s chief engineer faces charges of his own. District Court Judge Ralph Beistline imposed $205,000 in criminal … Continue reading

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Should you challenge OSHA citations?

Will Kramer has written an excellent article on why you should challenge OSHA citations. Based on an analysis of the more than 57,000 citations listed in OSHA’s public inspection databases in 2012, employers achieved an average penalty reduction of 49% … Continue reading

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