OSHA Combustible Dust Rulemaking
Thursday, January 28th, 2010Stakeholder Comments on OSHA Combustible Rulemaking from John Astad's blog.
Archive for the ‘Regulations’ Category
Stakeholder Comments on OSHA Combustible Rulemaking from John Astad's blog.
Industrial Safety in Slumdog Millionaire Nation
Monday, October 19th, 2009According to the International Labor Organization (ILO), there were 11 deaths every 100,000 workers in India in 2005. This number was two in the US and 0.01 in Japan. What is scary is that the number of fatalities may be significantly underestimated because of absence of a formal accident tracking ...
OSHA NEP Fines
Wednesday, October 14th, 2009OSHA inspected 42 refineries between June 2007 - February 2009. Below is a summary of violations for 30 refineries. [Table=12] The average penalty for each violation is $ 5,650. The average penalty per refinery is $ 98,300. Contrast these numbers with $700 million that cost BP for fatality and personal injury claims related to ...
Is the Chemical Safety Board (CSB) Positively Impacting Process Safety?
Wednesday, October 7th, 2009CSB’s approach to chemical accident investigation is a step further than OSHA’s. CSB gathers background information about the accidents, performs a detailed root cause study, and makes recommendations to appropriate stakeholders. Great approach to a complex issue...but CSB’s strategy following the investigation leaves a lot to be desired. The hope from ...
Where’s the Training Material from OSHA Grants?
Monday, October 5th, 2009Interesting post by John "Dust Explosion" Astad. Where's the Beef? Previous Training Material
Regulating Reactive Chemicals
Friday, October 2nd, 2009Recently, members of Congress sent a letter to OSHA chief, Jordan Barab, to expand PSM standard to address reactive chemicals. Reactive chemicals have gained increasing attention since the Chemical Safety Board (CSB) released its report on reactive chemicals in 2002. Now I have been working in the area of reactive chemicals ...
CSB: To Investigate Or Not To Investigate
Wednesday, September 16th, 2009Last year, the Government Accountability Office (GAO) reported that the Chemical Safety Board (CSB) is not meeting its statutory mandate by investigating major chemical accidents. CSB’s Statutory Mandate The Clean Air Amendment Act (CAAA) of 1990 directs CSB to (1) investigate and report on the cause or probable cause of any accidental chemical ...
OSHA Chemical NEP
Monday, September 14th, 2009On July 27, 2009 OSHA launched its National Emphasis Program (NEP) targeted at chemical facilities. The NEP will operate as a one-year pilot program during which OSHA will conduct planned inspections of chemical facilities. Which Chemical Facilities Will Be Reviewed? The Chemical NEP will focus on facilities in the following regions: Regions ...
Have You Considered Inherently Safer Alternatives?
Wednesday, September 2nd, 2009Inherently safer philosophy represents a slightly different approach to risk mitigation. Instead of focusing on mitigating risks, an inherently safer alternative focuses on eliminating the hazards.Let us look at couple of inherently safer examples. HF Alkylation There are four alternatives available to perform alkylation: Pure HF: Potential high ...
RAGAGEP
Monday, August 10th, 2009RAGAGEP stands for Recognized And Generally Accepted Good Engineering Practices. Specifically, OSHA 29 CFR 1910.119 (D)(3)(ii) states:The employer shall document that equipment complies with recognized and generally accepted good engineering practices. EPA RMP also refers to RAGAGEP in 40 CFR 68.73:Inspection and testing procedures shall follow recognized and generally accepted good engineering ...
