Today, the Occupational Safety and Health Administration (“OSHA”) announced a final rule that will make information regarding workplace injuries and illnesses available online. OSHA already requires many employers to keep a record of injuries and illnesses, but little or no information about worker injuries and illnesses at individual employers is made public. The new regulation
EPA’s Proposed Revisions to RMP Rules have Arrived
The Environmental Protection Agency (“EPA”) published a Request for Information (“RFI”) on July 31, 2014 relating to possible changes to the Risk Management Program (“RMP”) rules codified at 40 C.F.R. Part 68. See 79 Fed. Reg. 44604 (July 31, 2014). On June 19, 2015, OSHA, the EPA, and the Department of Homeland Security held a…
Awaiting the Arrival of Proposed Revisions to OSHA PSM and EPA’s RMP Rules: New OSHA Policy Statement Defining RAGAGEP
The Occupational Safety and Health Administration (“OSHA”) published a Request for Information (“RFI”) on December 9, 2013 concerning possible changes to the Process Safety Management (“PSM”) program codified at 29 C.F.R. 1910.119. See 78 Fed. Reg. 73756 (Dec. 9, 2013). Likewise, the Environmental Protection Agency (“EPA”) published an RFI on July 31, 2014 relating…
Awaiting the Arrival of Proposed Revisions to OSHA PSM and EPA’s RMP Rules: Expanding Mechanical Integrity to Cover Any Safety-Critical Equipment
The Occupational Safety and Health Administration (“OSHA”) published a Request for Information (“RFI”) on December 9, 2013 concerning possible changes to the Process Safety Management (“PSM”) program codified at 29 C.F.R. 1910.119. See 78 Fed. Reg. 73756 (Dec. 9, 2013). Likewise, the Environmental Protection Agency (“EPA”) published an RFI on July 31, 2014 relating…
Awaiting the Arrival of Proposed Revisions to OSHA PSM and EPA’s RMP Rules: Requiring Third-Party Compliance Audits
The Occupational Safety and Health Administration (“OSHA”) published a Request for Information (“RFI”) on December 9, 2013 concerning possible changes to the Process Safety Management (“PSM”) program codified at 29 C.F.R. 1910.119. See 78 Fed. Reg. 73756 (Dec. 9, 2013 ). Likewise, the Environmental Protection Agency (“EPA”) published an RFI on July 31, 2014 relating…
Awaiting the Arrival of Proposed Revisions to OSHA PSM and EPA’s RMP Rules: Mandatory Updating of Defining RAGAGEP
The Occupational Safety and Health Administration (“OSHA”) published a Request for Information (“RFI”) on December 9, 2013 concerning possible changes to the Process Safety Management (“PSM”) program codified at 29 C.F.R. 1910.119. See 78 Fed. Reg. 73756 (Dec. 9, 2013). Likewise, the Environmental Protection Agency (“EPA”) published an RFI on July 31, 2014 relating…
Awaiting the Arrival of Proposed Revisions to OSHA PSM and EPA’s RMP Rules: Defining Recognized and Generally Acceptable Good Engineering Practices
The Occupational Safety and Health Administration (“OSHA”) published a Request for Information (“RFI”) on December 9, 2013 concerning possible changes to the Process Safety Management (“PSM”) program codified at 29 C.F.R. 1910.119. See 78 Fed. Reg. 73756 (Dec. 9, 2013). Likewise, the Environmental Protection Agency (“EPA”) published an RFI on July 31, 2014 relating…
Awaiting the Arrival of Proposed Revisions to OSHA PSM and EPA’s RMP Rules: Atmospheric Storage Tanks
The Occupational Safety and Health Administration (“OSHA”) published a Request for Information (“RFI”) on December 9, 2013 concerning possible changes to the Process Safety Management (“PSM”) program codified at 29 C.F.R. 1910.119. See 78 Fed. Reg. 73756 (Dec. 9, 2013). Likewise, the Environmental Protection Agency (“EPA”) published an RFI on July 31, 2014 relating…
What is Meant by the Requirement to Resolve the Team’s Findings?
Both PSM and RMP require that the owner or operator have a system in place to promptly address the team’s PHA findings and recommendations to assure they are resolved in a timely matter. See 29 CFR 1910.119(e)(5) and 40 CFR 68.67(e). In accordance with Pre-startup review requirements, these PHA recommendations must be resolved or implemented…
How Much Time Do I Have to Implement an Accepted Recommendation?
After the team makes a recommendation, the first step is to resolve the team’s finding. If the resolution is to accept the recommendation, the employer must complete the actions as soon as possible. See 29 CFR 1910.119(e)(5).
OSHA expects that accepted recommendation be completed as soon as possible which usually means with one to…