By Philip L. Comella and Craig B. Simonsen

iStock_000049177646MediumThe U.S. Environmental Protection Agency has promulgated significant new provisions both to its 1988 underground storage tank (UST) regulations and to its 1988 state program approval (SPA) regulations. 80 Fed. Reg. 41566 (July 15, 2015). This is the first major revision to the federal UST regulations since

By Brent I. Clark and Craig B. Simonsen

PSM Blog PicOSHA has just published a Standard Interpretation (Interpretation) to provide guidance on the enforcement of the Process Safety Management (PSM) Standard’s “recognized and generally accepted good engineering practices” (RAGAGEP) requirements, including how to interpret “shall” and “should”  language in published codes, standards, published technical reports, recommended practices,

By James L. Curtis and Craig B. Simonsen

The teenage summer job working at the local store is a rite of passage in most communities. Almost everyone has held a summer job at some point in their life.  However, given the disturbing rise in workplace violence, teenagers can be swept up in hostile situations and