Practice and Industry Groups

D.A. Duggar

Of Counsel Washington D.C.

D.A. Duggar’s practice is focused on OSHA’s Process Safety Management and EPA Risk Management Plan compliance issues.

Prior to becoming an attorney, D.A. was a process engineer in the petrochemical industry for almost a decade.  During this time, D.A. developed process safety information, participated in numerous PHAs, wrote operating procedures, trained operations personnel on new equipment and new product lines, completed MOCs, conducted PSSRs, served on incident investigation teams and assisted with compliance audits.  Now, D.A. counsels clients with PSM citations, RMP notices of violation, facility-siting issues, and RAGAGEP compliance questions.


Experience

  • Counsel for entities cited under OSHA’s PSM Standard and entities that received a notice of violation issued under the EPA’s RMP Rule.
  • Primary author of an amicus brief filed with the Occupational Safety & Health Review Commission discussing RAGAGEP as understood within the PSM Standard.
  • Counsel regarding comments submitted in response to OSHA’s request for information on potential revisions to its PSM Standard and comments submitted in response to the EPA’s request for information on potential revisions to its RMP regulations and related programs.
  • Counsel regarding comments submitted in response to the State of California Department of Industrial Relations proposed General Industrial Safety Order 5189.1 addressing Process Safety Management for Refineries.
  • Counsel regarding insurance claims involving Law and Ordinance Coverage (aka Code Upgrade Coverage) provisions and OSHA’s PSM Standard, particularly as they relate to facility siting and/or changes in RAGAGEP.
  • Counsel to fuel distribution terminals regarding the applicability of OSHA’s PSM Standard as it relates to butane injection systems and the boundaries of the covered process.
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April 27, 2017 - Inside OSHA Online - "OSHA Urged To Retain Poultry Sector Enforcement Due To 'Severe' Injuries"
March 16, 2017 - Inside OSHA Online - "Worker Safety Programs Face Severe Cuts Under Trump's FY18 Budget"
January 13, 2017 - Inside OSHA Online - "5th Circuit Ruling Limiting OSHA Oversight May Spur EPA RMP Enforcement"

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