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I am proud to announce that SAFTENG and The Chlorine Institute have renewed our partnership for another year (through 2026).  Members of The Chlorine Institute receive a FREE SAFTENG membership.  If you qualify, please contact me

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Catchy names for programs can do more damage than the actual program
Several years back, I worked with an organization that had an in-house Operational Testing program with a really catchy name. I actually loved the name, but as I learned more about the process, it was simply a catchy name for a very bad process. It was an attempt by a business to have BOTH a Behavior-Based Safety Process (BBS) and a Skills Testing program required by the government agency that regulated...
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Requirements for our BULK Tranfer Hoses in a PSM/RMP Process
Recently, I had the opportunity to help a client gain the full picture of what has to be done regarding the BULK TRANSFER hoses to unload their HHC/EHS from Tanker Trucks/ISO Containers and Railcars. Now, before we get into the specifics, I know a number of folks will fall back on the compliance position that unloading/loading our HHCs/EHSs are DOT-regulated functions. Through my career, I have learned...
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Evacuating the Hazardous Materials to achieve a ZES can be more dangerous than the actual maintenance
Last week, David Ayers, Ph.D., CSP, CHMM, and I had a nice chat regarding LOTO and Complex Processes, and one of the areas associated with these LOTOs is the “evacuation” of the HAZMAT within the process/system. We did not have enough time for me to get deep into the weeds on this aspect of isolating a Process/System, so this is my attempt to explain what needs to be done. 1st and most important,...
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PRCS Attendant Training... how far should we take it?
In our PSM/RMP and OSH audits, we always spend more time on the Life Safety Standards, such as PRCS, LOTO, LEO, Respiratory Protection, etc. One of the most common errors we find in these audits is the lack of training for the attendants. It’s not that they are not meeting 1910.146(i)(1) – 1910.146(i)(10) training obligations; it’s that they are missing the KEY ROLE most businesses...
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Static Electricty the cause of a Flash Fire destroying gasoline storage tank (Video)
An explosion at a large outdoor oil storage tank at Korea National Oil Corporation Pipeline’s Yeongnam branch is preliminarily attributed to static electricity generated during a petroleum component verification process. The incident occurred at a large-scale oil storage facility housing 12 to 14 tanks, raising concerns that it could have escalated into a major disaster. During an on-site briefing,...
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Does a Class IIIA Flammable Liquid require the area to be a HAZLOC
We see this often, handling, storing, and processing a Class IIIA flammable liquid, and about half will classify the area, and the other half do not. So who is right? Here is my take on the matter as I work thru the risk analysis… … HomeRead More »
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PRCS Fatality (HAZ ATM benzene and toluene)
OSHA has cited a petroleum tank services contractor for exposing workers to chemical and respiratory hazards after an employee was fatally exposed to benzene and toluene when they entered a fuel storage tank in July 2025. Investigators cited the company with 12 serious violations for failing to develop and implement a written permit-required space entry program, ensure those authorized to enter the...
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OSHA answers two (2) big questions about medical evaluations for Respirators
Question 1: To what extent does OSHA’s Respiratory Protection standard, at 29 CFR § 1910.134(e), require that the PLHCP’s medical evaluation for respirator use include consideration of factors beyond respiratory protection that affect fitness to safely perform the expected job tasks while wearing a respirator? Question 2: Is there a reasonable expectation that the employer will provide...
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OSHA publishes "7-Step Guide" for its Safety Champions program
The Safety Champions Program (SCP) assists employers in developing and implementing a robust safety and health program (SHP). The main goal of safety and health programs is to prevent workplace injuries, illnesses, and deaths, as well as the suffering and financial hardship these events can cause for workers, their families, and employers. The SCP is a voluntary cooperative program and operates separately...
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Line Break gone bad (Refrigerants)
OSHA has cited a Florida plumbing, heating, and air conditioning contractor for exposing workers to struck-by hazards after an employee suffered a fatal injury at a Bal Harbor Shops worksite in August 2025. OSHA found that on Aug. 28, 2025, a pipefitter installing a new air-conditioning system for a mall expansion construction project was fatally injured by a pressurized HVAC piping system. The...
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Hearing Protector Fit Testing: Ensuring Appropriate NoiseProtection at Work
Hearing protector fit testing (HPFT) is a critical advancement in workplace hearing conservation and is recognized as a best practice (OSHA et al., 2008; OSHA, 2017). HPFT is not required under OSHA’s Occupational Noise Exposure standards (29 CFR 1910.95; 29 CFR 1926.52), but can be a valuable training tool for workers. HPFT measures the amount of noise reduction (attenuation) a hearing protection...
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Line Break gone Bad (HF Acid - CCPS Beacon 03/26)
I have written about this incident a couple of times, as it is full of learning opportunities. The biggest of which is the practice of REDUCING PPE after the initial opening was uneventful, and we have “verified” our positive means of isolation is holding. This is a common practice for long-duration jobs and plays a role in heat stress management. Basically, we are leveraging the positive...
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