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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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Fireproofing piping supports
Fireproofing piping supports — specifically the application of Passive Fire Protection (PFP)— is a critical mitigation strategy designed to prevent the structural collapse of pipe racks during a flammable liquid fire. In most state fire codes and the IFC, flammable liquid piping supports inside a secondary containment are REQUIRED to be protected from the effects of a pool fire. … HomeRead...
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Does federal OSHA require a "swing gate" at a vertical point of ladder access at the edge of a walking/working surface?
The simple answer is yes. Federal OSHA requires either a self-closing swing gate or an offset barrier at the point of access where a fixed ladder meets the unprotected edge of a walking-working surface. While the regulatory text in Subpart D sometimes causes confusion by referring to these access points as “holes,” OSHA consistently enforces the gate requirement at perimeter edges to maintain...
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PHMSA issues guidance on NH3 Nurse Tank Non-Destructive Testing
In February 2024, the Federal Motor Carrier Safety Administration (FMCSA) and PHMSA issued a safety advisory to provide notice of the possibility of catastrophic failure of nurse tanks. This notice focused on nurse tanks manufactured from January 1, 2007, through December 31, 2011, by American Welding and Tank (AWT) at its Fremont, Ohio plant. Nurse tanks manufactured by AWT from 2009 to 2010 were...
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Preventing Hearing Loss Caused by Chemical Exposures (Ototoxicity)
Think about… when we are working around chemicals, we typically look at forms of exposure such as inhalation, absorption through the skin, etc., and we wear the appropriate PPE. For example, we may wear a full-face respirator, gloves, and an apron to protect against splash and vapors. But there is one organ that is normally not part of this chemical hazard PPE assessment. Can you guess which...
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How detailed should our means to verify ZES be?
This is a pet peeve of mine: DETAILS MATTER in safety procedures and safe work practices. One thing we commonly find is some very generic language in LOTO procedures for how to verify each energy source has been isolated and is at a Zero Energy State (ZES). For example, you’re performing a “periodic inspection,” and during the inspection, you observe the worker throw the disconnect...
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OSHA cites big rig parts distributor for confined space fatality (asphyxiation), safety hazards after worker fatality at the company’s Corpus Christi facility
OSHA has cited a big rig parts distributor for 16 serious safety violations after an investigation into a worker fatality found the company exposed workers to confined space and other safety hazards. OSHA initiated an inspection on Jan. 7, 2026, after an employee asphyxiated while inspecting a tanker trailer. OSHA cited the company for 16 serious and three other-than-serious safety violations,...
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The double H2S fatality event at a Kraft Mill is the classic anatomy of an accident - CSB Issues Woodland Pulp Investigation Update
This is WHY we need the CSB! We would never get this type of analysis from an OSHA investigation/report. No offense to my friends at OSHA, its just this type of analysis and passing on the critical information is not part of their charter. Today, the U.S. Chemical Safety and Hazard Investigation Board (CSB) released an update on the agency’s ongoing investigation into the January 27, 2026, fatal...
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Pressure testing piping and the connected vessels
Every once in a while, I come across a process design that leads to code issues down the road. This usually occurs with small pressure vessels (e.g., less than 5 cubic ft) that fall outside the scope of ASME Section VIII and also fall outside the scope of being a “confined space” (e.g., too small to bodily enter). So the business did not provide a means to isolate the vessel for maintenance...
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Would the risk management program regulations cover the loading and unloading of transportation containers?
The definition of stationary source includes transportation containers used for storage not incident to transportation and transportation containers connected to equipment at a stationary source for loading or unloading (40 CFR Section 68.3). In a January 6, 1998 final rule (63  FR 640), EPA clarified that if a container remains attached to the motive power that delivered it to the site,...
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For CAA section 112(r)(1), General Duty, what are the chemicals that are covered?
There is no specific list of substances that subjects a stationary source owner or operator to the general duty provisions. The general duty provisions apply to owners and operators of all stationary sources that have any “extremely hazardous substances”. Extremely hazardous substances are NOT limited to the list of regulated substances listed under section 112(r), nor the extremely hazardous...
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Must separate amounts of regulated substances be aggregated for threshold determinations?
Drums containing regulated substances (listed in 40 CFR §68.130) are stored in several separate locations at a stationary source and there is no possibility that an accidental release in any of the individual storage areas would impact any of the other storage areas. Must the overall amount of the regulated substance present at the stationary source be considered when determining whether the threshold...
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When your "life safety equipment" inspector is violating your HAZLOC requirements!
PLEASE ensure your “life safety” contractor inspector for Exits, Fire Extinguishers, EW/SSs, etc., is FULLY trained on the hazards of the area(s) they will be working in. This year, we have found two (2) national companies that provide these inspection services using electronic devices NOT rated for the hazardous areas where they are working. We got every excuse anyone could come up...
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