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Tag Archives: OSHA
What can we learn from the Fernie Ammonia fatalities?
The October 17th, 2017 Ammonia release in Fernie, BC resulted in three fatalities: On October 16, 2017, the curling brine chiller at the Fernie Memorial Arena was put back into operation after a seasonal shutdown. During the shutdown and seasonal … Continue reading
Posted in Community Involvement, General Duty, Incidents
Tagged EPA, General, Incidents, Mechanical Integrity, Operator Training, OSHA, PSM, RMP
Comments Off on What can we learn from the Fernie Ammonia fatalities?
Is a condenser change a Replacement in Kind?
The Question: Imagine a project where you are going to replace an existing condenser with a newer model. Does this “change” trigger the MOC element or does it fall into the Replacement in Kind exemption to the MOC requirement? This … Continue reading
Posted in Compliance, EPA, IIAR, Management of Change, OSHA
Tagged EPA, Management of Change, OSHA, PSM, RAGAGEP, RMP
Comments Off on Is a condenser change a Replacement in Kind?
Learning from Failure
“Failure is only opportunity to begin again. Only this time, more wisely.” –Henry Ford We often push PSM practitioners to perform Incident Investigations for fairly minor events in the hopes that the lessons learned from those minor incidents will stop … Continue reading
Posted in Culture, General Information, Good Engineering Practices, Incidents, OSHA, System Optimization
Tagged Incidents, Lessons Learned, OSHA, PSM, RAGAGEP, RMP
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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
Posted in Compliance, General Duty, General Information, NEP, OSHA
Tagged Fines, NEP, OSHA, PSM
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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
Posted in Community Involvement, Compliance, General Duty, Good Engineering Practices
Tagged DHS, EPA, Fines, General Duty, OSHA
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RAGAGEP Hierarchy in Application – A worked example
RAGAGEP (Recognized and Generally Accepted Good Engineering Practices/Principles) is extremely important to our Process Safety programs as it helps define the boundaries of what is (and isn’t) acceptable in our processes and our management of them. There seems to be … Continue reading
Posted in Compliance, EPA, Good Engineering Practices, Management of Change, OSHA
Tagged EPA, Mechanical Integrity, OSHA, PSM, RAGAGEP, RMP
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What training does my refrigeration operator need?
Note: this article focuses only on the PSM/RMP training burden that is unique to PSM/RMP. Furthermore, it does not address the requirements of training documentation. Understanding the requirements of PSM/RMP training for Operators The Training element in PSM (1910.119(g)) and … Continue reading
Posted in EPA, Operator Training, OSHA, Training
Tagged Employee Involvement, EPA, Mechanical Integrity, Operator Training, OSHA, PSM, RMP
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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
Posted in Compliance, Inspections, OSHA
Tagged EPA, Fines, OSHA, PSM, RMP
Comments Off on Why OSHA’s Statute of Limitations doesn’t really matter in PSM/RMP
How to get Willful OSHA Citations & Fines
The incident we are discussing today is from a recent ruling in the United States Court of Appeals, Seventh Circuit where they recently denied a petition for review in the case of “DANA CONTAINER, INC. v. SECRETARY OF LABOR.” While this … Continue reading
Posted in Community Involvement, Compliance, OSHA
Tagged Incidents, OSHA
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Why does my PSM program make me review the PHA during any equipment/facility MOC?
Nearly two years ago, I changed the Management of Change Written Plan template in my PSM programs to make a few changes: Removed the “minor change” and “major change” categories. Explicitly require a Process Hazard Analysis review during all equipment/facility … Continue reading
Posted in Compliance, EPA, Good Engineering Practices, Management of Change, OSHA
Tagged EPA, Management of Change, OSHA, PSM, RMP
Comments Off on Why does my PSM program make me review the PHA during any equipment/facility MOC?