As we noted in the previous weeks on the Work Knowledge Blog, employers may see a marked increase in OSHA inspections in the coming months due to the agency’s focus on PSM related issues. This focus includes proposed revisions to OSHA’s appropriations language to allow for PSM audits of small establishments and various contemplated changes … Continue reading this entry
Tags: #Gardere, 29 C.F.R. § 1903.9, 29 C.F.R. § 1910.119, 29 U.S.C. § 657, 29 U.S.C. § 664, appropriations, civil penalty, criminal referral, facility tour, inspection, interview, investigation, legal representation, Occupational Safety and Health Administration, OSHA, process safety management, PSM, rights, Taylor White, Trade Secrets, walkaround, work knowledge
On June 2, 2016, the Occupational Safety and Health Administration (“OSHA”) convened the Small Business Advocacy Review Panel (“SBAR Panel”) in accordance with the Small Business Regulatory Enforcement Fairness Act. The SBAR Panel was convened as a follow-up to Executive Order 13650 entitled “Improving Chemical Facility Safety and Security” (the “EO”). The EO stated that … Continue reading this entry
Tags: #Gardere, 29 C.F.R. § 1910.119, chemical safety, enforcement, Environmental Protection Agency, EPA, Executive Order 13650, exemption, process safety management, PSM, RAGAGEP, Risk Management Plan, RMP, root cause, SBAR, SER, small business advocacy review panel, small businesses, small entity representatives, Taylor White, work knowledge
Last week, we outlined that OSHA’s proposed appropriations language revisions for FY 2017 may signal increased inspections, particularly PSM audits, for certain employers in Region 6, which includes Texas, Oklahoma, Arkansas, Louisiana, and New Mexico. Employers have an opportunity to get and stay prepared now for this possible inspection glut. To that end, over the … Continue reading this entry
Tags: #Gardere, 29 C.F.R. § 1910.119, appropriations, audit, Best Practices, Compliance, document retention, Documentation, inspection, investigation, Occupational Safety and Health Administration, OSHA, policies, procedures, process safety management, PSM, region 6, safety information, Taylor White, Tips, training, work knowledge
With all the changes from the Occupational Safety and Health Administration (“OSHA”) over the last year or so, employers need to get prepared for increased inspections and safety audits in the near future. This is especially true with the appropriations language revisions OSHA has proposed for FY 2017. OSHA’s stated purpose for its proposal is, among … Continue reading this entry
Tags: #Gardere, 29 C.F.R. § 1910.119, appropriations, audit, Best Practices, Compliance, inspection, investigation, Occupational Safety and Health Administration, OSHA, policies, procedures, process safety management, PSM, safety information, Taylor White, work knowledge
On May 11, 2016, the Occupational Safety and Health Administration (“OSHA”) issued a Standard Interpretation on the topic of Recognized and Generally Accepted Good Engineering Practices (“RAGAGEP”) in Process Safety Management (“PSM”) Enforcement. This new interpretation replaces an interpretation of the same title dated June 5, 2015. In replacing it though, OSHA does not make … Continue reading this entry
Tags: 29 C.F.R. § 1910.119, compliance health and safety officers, CSHO, Good Engineering Practices, occupational safety, Occupational Safety and Health Administration, OSHA, OSHA RAGAGEP, OSHA Update, process safety management, PSM, PSM enforcement, RAGAGEP, ragagep internal procedures, RAGAGEP Interpreation, ragagep standard interpration, Recognized and Generally Accepted Good Engineering Practices
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