Recent Blog Posts

CalOSHA and Emergency Escape Breathing Apparatus

July 9th, 2019

Over the past year, CalOSHA has been educating the ammonia refrigeration industry regarding their expectation for complying with the Emergency Action Plan (EAP) requirement for “procedures to be followed by employees performing rescue or medical duties” (Title 8 CCR §3220(b)(4)). CalOSHA has made it clear that they expect ammonia refrigeration facilities to have rescue capabilities, […]

Yoke and Adapter Ruling

January 1st, 2019

Recently an Administrative Law Judge settled a long-standing issue that has been frustrating the sulfur dioxide industry. For the past several years, CalOSHA has been routinely citing facilities that utilize a union adapter to connect to a sulfur dioxide ton container. CalOSHA’s basis for citation has been failure to comply with recognized and generally accepted […]

Keys to a Successful PSM Inspection

July 26th, 2016

A PSM inspection[1] is about as appealing as a colonoscopy; at least that’s what I’ve ascertained from the numerous clients who have called me, frantic for help and counsel. For those who have been around the PSM/RMP world for any amount of time, we all recognize the stakes are high and the fines can be […]

Overview of Federal and California Process Safety Regulations (Part 2 of 3)

January 5th, 2016

This is a continuation of our blog series titled Overview of Federal and California Process Safety Regulations. Part 1 can be accessed here. Fed/OSHA PSM vs. Cal/OSHA PSM Fed/OSHA’s Process Safety Management (PSM) and Cal/OSHA’s Process Safety Management (PSM) regulations are very similar in scope and intent. Two (2) important differences are summarized below: Compliance […]