Tag Archives: OSHA

Should you challenge OSHA citations?

Posted on February 3, 2014 by Brian Chapin

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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H.R.1648 – Protecting America’s Workers Act

Posted on November 29, 2013 by Brian Chapin

Rep. Miller, George [D-CA-11] has introduced legislation to revise the OSHA penalty structure. There are some interesting changes in this legislation: Repeat Violations – Increased from $70,000 to $120,000 Serious Violations – OSHA has requested increase from $7,000 to $12,000. … Continue reading →

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How do I deal with recommendations to my program?

Posted on September 29, 2013 by Brian Chapin

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 →

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OSHA is going to have a field day in 2016

Posted on September 7, 2013 by Brian Chapin

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 →

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OSHA to revise Palmer guidance on Hydrostatic Trapping

Posted on August 30, 2013 by Brian Chapin

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 →

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OSHA to focus on difficult inspections (like PSM) in 2014

Posted on August 20, 2013 by Brian Chapin

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 →

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The three levels of PSM Compliance…

Posted on August 15, 2013 by Brian Chapin

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 →

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What does OSHA think is the biggest concern in ammonia refrigeration components?

Posted on August 9, 2013 by Brian Chapin

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 →

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Are Oil Separators a Confined Space?

Posted on February 8, 2013 by Brian Chapin

Quite a few people have been reporting that OSHA inspectors and consultants are making an issue of people not classifying their compressor oil separators as a confined space. This is vexing because unless your oil separators are “large enough and … Continue reading →

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The real cost of an OSHA/EPA fine isn’t the check you write

Posted on November 15, 2012 by Brian Chapin

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 →

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