Chemical Security Program Statistics as of November 1, 2014
The Department of Homeland Security (DHS) continues to strengthen security at the Nation’s high-risk chemical facilities through the Chemical Facility Anti-Terrorism Standards (CFATS) program. Chemical Security Program Statistics as of November 1, 2014...
2014 Video of the Week #49 (Loose Clothing around powered equipment)
WARNING! This video shows a dog in distress for a short time. The dog is fine as can be seen at the end of the video, but it will raise your blood pressure! I am sharing this video to show everyone the strength of an elevtaor and what happens when something is caught in the door; in this instance it was the Lab's leash. This is why LOOSE FITTING CLOTHING, especially items such as ties and scarfs pose a significant hazard around rotating equipment.
EPA RMP Citations @ a latex resin manufacturing plant (vinyl acetate monomer; $47K)
Respondent does business in the State of Alabama. Respondent operates a "stationary source" that has one RMProgram covered process, latex resin manufacturing, which stores or otherwise uses vinyl acetate monomer in an amount exceeding its applicable threshold of 15,000 pounds. Respondent has submitted and registered an RMPlan to the EPA for the stationary source identified in Paragraph 5 of this CAPO. Respondent has developed an RMProgram accidental release prevention program for the stationary source. Based on an RMProgram compliance monitoring investigation initiated by EPA on July 25-26, 2013, the EPA alleges that the Respondent violated the CAA Chemical Accident Prevention Provisions, because Respondent did not adequately implement provisions of 40 CFR Part 68 when it:
OSHRC decision on Combustible Dusts (OSHA Dust Sampling, Chain of Custody, Knowledge of hazards, and Signage for ComDust areas)
Facility manufactures over 600 small animal products, including bird food, but not dog and cat food, which are sold in small and large chain pet stores. Fifty to 60 employees work in its 120,000 square foot production facility and warehouse. Part of the facility, measuring 8,000 to 10,000 square feet, is devoted to assembling small animal products from 2500 types of raw materials, including millet seeds, milo, safflower seeds, sunflower seeds, corn, wheat, oats, papaya, pineapple, flaked peas, raisins, dates, corn flakes, banana chips, flower petals, and poppy seeds. Adjacent to this assembly room, located on an outside corner of the first floor of the facility, is the “dust room,” which is the focus of this case. In another part of this facility, located away from the dust room, is the “hay room,” which is devoted to hay-related products. The hay room is about 1500 square feet and was the focus of a previous OSHA inspection in 2008.
OSHRC decisions on Machine Specific LOTO Procedures, LOTO Periodic Inspections, and LOTO Training for Affected/Other employees
These LOTO decisions by the OSHRC are HUGE in establishing some "minimums" for LOTO procedures, periodic inspections, and training for "affected" and "other" employees. Readers should pay very close attention to the details that OSHA used in their arguments of how poorly "machine specific procedures" were written (missing data, conflicting data, no magnitudes listed, etc.). The facility really wasted the courts time with their arguments (my professional opinion) as OSHA had their ducks in a row AND the facility made it easy for OSHA... i.e. plenty of low hanging fruit for OSHA to pick from within their LOTO program!!! Here are the LOTO decisions:
NOTE: this case also involved a machine guarding decision that can be seen in the full decision.
EPA RMP Citations @ Cold Storage Facility (NH3; $124K)
Respondent owns and operates a controlled-temperature storage warehouse for food products. The Facility is located adjacent to Interstate 91 and east of the Quinnipiac River, within a mile of numerous shops and business and approximately 1 mile from several schools. Respondent uses anhydrous ammonia in a refrigeration "process". In 2009, Respondent filed a Program 3 RMP for the Process and reported that it used 22,600 pounds of anhydrous ammonia. Respondent's most recent RMP re-submission, in 2013, again reported that one Program 3 process uses 22,600 pounds of ammonia. Accordingly, the Process is a "covered process" subject to the provisions of Part 68 because Respondent "uses," "stores," and "handles" the RMP chemical anhydrous ammonia at the Facility in an amount greater than 10,000 pounds. According to Respondent's RMP, there are public receptors within the distance to the endpoint for a worst case release of the amount of anhydrous ammonia used in the Process. Likewise, modeling performed by EPA indicates that the endpoint for a worst case release from each Process is greater than the distance to a public receptor. Additionally, the Process is subject to OSHA's PSM requirements at 29 C.F.R. § 1910.119 because it uses anhydrous ammonia in an amount over the threshold quantity of 10,000 pounds. Therefore, in accordance with 40 C.F.R. § 68.10(a}-(d), Respondent's use, storage, and handling of anhydrous ammonia in its Process is subject to the requirements of RMP Program 3. On October 18, 2012, EPA inspectors visited the Facility ("Inspection") to assess Respondent's compliance with Section 112(r) of the CAA and with Sections 302-312 of the Emergency Planning and Community Right-to-Know Act. Here is a breakdown of the citations:
OSHA's First Aid and BBP training requirements
A very common question we get during our work is... "Am I required to have a first aid team on site?" And "If I am, do they fall under the Blood Borne Pathogen standard"? OSHA actually provided us some great insight into their position on these questions in a 2007 LOI. They stated...
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