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While there are numerous OSHA regulations that requires facilities to maintain written safety programs, many of you may be unaware of exactly which programs you are required to maintain. You may ask yourself “Do I need to have a written program for every single OSHA regulation?” One thing that is good to ask yourself is are you confident and prepared if OSHA visits your facility and inspects your safety programs? This list of safety programs and some of the aspects that are required to be outlined in them should provide guidance on what to keep in mind when deciding how to prioritize your safety programs. Continue reading “5 Must Have Safety Programs”

Almost all facilities that store more than 1,320 gallons of petroleum products in above ground storage tanks (AST’s) and oil filled operating equipment or 42,000 gallons in underground storage tanks (UST’s) are required by the U.S. Environmental Protection Agency (US EPA) to have a Spill Prevention Controls and Countermeasures (SPCC) Plan. These 6 routine requirements are important for maintaining a compliant SPCC: Continue reading “Top 6 SPCC Requirements You Should Be Following”

Many people in general industry are all too familiar with some of the vague or confusing requirements in OSHA’s lockout/tagout regulation 1910.147. In my years working with Conversion Technology, and visiting all sorts of different manufacturing sectors, there have been several mistakes and misconceptions regarding lockout/tagout that have popped up. Continue reading “8 Mistakes to Avoid to Ensure an Effective Lockout/Tagout Program”

creekAs we reported in an earlier blog post, the Georgia Environmental Protection Division (GAEPD) has posted a draft of the 2017 NPDES General Permit No. GAR050000 for Storm Water Discharges Associated with Industrial Activity. The current (2012) version of the permit is set to expire on May 31, 2017, and this revision will replace it. The GAEPD has held three stakeholder meetings that were open to the public, and representatives from CTI were in attendance. There are a few obvious trends that we can see from the direction the GAEPD is heading. Most notably, there is an increased focus on erosion and sedimentation control, and there is a push for higher accountability in completing corrective actions. We will discuss both of these below, but keep in mind that the permit is in an early draft phase.  The GAEPD will be issuing a second draft based on input received during the stakeholder meetings and the preliminary comment period, and there will be a second opportunity for the public to comment before the final permit is issued.  Continue reading “Update on Georgia’s Draft Industrial Stormwater General Permit”

The National Fire Protection Association (NFPA) is charged with creating standards for fire prevention in North America. While they have no enforcement power of their own, Authorities Having Jurisdiction (AHJs), including OSHA, will reference the NFPA standards in their own regulations. NFPA has had industry/commodity specific standards for combustible dusts for years, in some cases dating back to the early 1920’s. These include: Continue reading “NFPA Issues 2017 Revisions to Industry Specific Combustible Dust Standards”

Your injury and illness records are about to become public record!

ReportToOsha

The Occupational Safety and Health Administration (OSHA) has issued another final rule this year. This new rule on facility recordkeeping will require employers to electronically submit injury and illness data to OSHA each year. The data submitted will be made public as part of an OSHA public records database. This change, as expected, is causing much controversy with employers throughout general industry sectors.

The new rule will require facilities with 250 or more employees to electronically submit their injury and illness information, from OSHA forms 300, 300A, and 301, to OSHA each year. Continue reading “OSHA’s New Recordkeeping Rule”

Earlier this year, NFPA issued the 2017 edition of NFPA 499: Recommended Practices for the Classification of Combustible Dusts and of Hazardous (Classified) Locations for Electrical Installations in Chemical Process Areas. While “Chemical Process Areas” is identified in the title of the standard, the standard applies to chemical processing or mixing operations, which can include agricultural dusts, if mixing is occurring.The standard is a useful tool in classifying combustible dust areas as part of a Dust Hazard Analysis (DHA) as required by NFPA 652: Standard on the Fundamentals of Combustible Dusts. Continue reading “NFPA Issues 2017 Edition of NFPA 499”

As originally published in CTI’s Compliance Matters Newsletter – Summer 2015. By: Chris Frendahl and Jeff Davis, PE

On September 1, 2015, the National Fire Protection Association (NFPA) issued NFPA 652, Standard on the Fundamentals of Combustible Dust. NFPA 652 is the first step to creating a single, unified combustible dust standard that would apply to all facilities.

A significant number of industrial accidents have been associated with combustible dust flash fires and explosions. Historically, the hazards from combustible dust are often overlooked, in part due to facilities not understanding the hazards of combustible dust. However, there are other cases where the hazards are overlooked due to complacency or a general attitude of “that can’t happen here.” Continue reading “NFPA Issues NFPA 652: Standard on the Fundamentals of Combustible Dust”

If you have elected to comply with the Boiler MACT regulation through performance testing, the deadline for the broad majority of existing boilers to complete the performance testing was July 29th, 2016. For the sake of this blog entry, we’ll assume you have done this. (If not, you should contact us immediately and we can get you up to speed!) Continue reading “Submitting Results of Boiler MACT Performance Tests”