Tag: inspection

Report Identifies Ongoing Concerns at Indiana OSHA

An assessment of Indiana OSHA’s (IOSHA) progress in meeting performance goals paints a picture of a potentially floundering agency. Federal OSHA recently reported on its follow up Federal Annual Monitoring Evaluation (FAME), which assessed the state OSHA program’s progress in meeting goals identified in an evaluation last year. Current findings list staff shortages; problems with […]

Prepare for an OSHA Rapid Response Investigation: How to Conduct a Root Cause Analysis Without Raising Red Flags

By: Valerie Butera, Esq. Although OSHA’s new reporting rule has been in effect for less than a year, it has caused some major changes in the way that OSHA operates. Since the new reporting rule went into effect on January 1, 2015, OSHA has received 200 to 250 reports of work-related deaths, inpatient hospitalizations, amputations, […]

SPCC Regs and Oil Absorbent

Q. Should oil mixed with absorbent (from spill cleanup) be included in a facility’s oil inventory for SPCC purposes? Would it be considered as oil during an inspection?

Let’s Talk RAGAGEP and OSHA Enforcement

In December 2013, the Occupational Safety and Health Administration (OSHA) issued a Request for Information to be used in updating its process safety management (PSM) standard. One of the changes under consideration by OSHA was the addition of a definition for recognized and generally accepted good engineering practices (RAGAGEP)—a term that is used, but not […]

What are RAGAGEP? OSHA Defines a Critical PSM Term

In the wake of the Chevron Richmond Refinery fire in 2012, the U.S. Chemical Safety Board, the federal Occupational Safety and Health Administration (OSHA), and state agencies have stepped up their process safety management (PSM) recommendations and enforcement efforts. Federal OSHA had already initiated the Petroleum Refinery Process Safety Management National Emphasis Program (Refinery NEP) […]

Reg Requirements for Hazardous Waste Manifests

What are the regulatory requirements for making changes on hazardous waste manifests? Your question doesn’t specify whether you are the generator who is preparing the hazardous waste manifest or the designated facility (TSDF) that is receiving the hazardous waste shipment. Assuming you’re the generator, it is the generator’s responsibility to ensure that the shipment is […]

Are You Ready for Your Next RCRA Inspection?

How much do you know about RCRA inspections? By law, the U.S. EPA and other RCRA-authorized agencies can enter your premises, examine records, and take samples if you handle hazardous wastes. Don’t get caught unprepared.

Employer in Seattle Fined over $400K for Health and Safety Violations

Once again, a major health and safety violation has cost a company hundreds of thousands of dollars. In this case, a marine terminal operator in Seattle has been found to have multiple serious health and safety violations and is facing more than $400,000 in fines. Labor & Industries (L&I) recently cited the marine terminal operator […]