OSHRC on PSM, Guarding, and HAZCOM from a Refinery NEP
This decision covers several interesting items and sets a HUGE precedent for RESPONSIBILITY of PHA and Audit items from the PREVIOUS owners PHAs and Audits. The decision CONFIRMED that "utilities" within the process, in this case a "positive pressure unit" on a control room ventilation system, is a piece of COVERED EQUIPMENT. It also establishes minimums for when an employer uses "alternatives" to labeling each container of hazardous chemicals, being that the said containers were process vessels. The commission vacated two citations, which the machine guarding item involving an unguarded horizontal merely because OSHA could not show "exposure to the hazard" and an MOC citation since the use of steam lances was a "common occurrence at the refinery". The item regarding the PHA and Audit items from a previous employer/owner could be a HUGE precedent for future sales of facilities that have covered processes. Here is the case... |
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