Bryan

Flammable Gases & Flammable Cryogenic Fluids Emergency Shut-Off Requirements

As we have discussed, the Chemical Safety Board (CSB) issued a Safety Study (CSB Safety Study: No. 2024-01-H, Remote Isolation of Process Equipment) discussing the untapped advantages when Remote Emergency Shut-Off Valves are used in hazardous processing.  I have written about these requirements for all types of hazardous materials; this post is for Flammable Gases…...

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Did you know (OSHA Arc Flash)

According to OSHA’s 29 CFR 1910.333 standard, “Conductors and parts of electric equipment that have been deenergized but have not been locked out or tagged … shall be treated as energized parts.” Even below 240V, arc flashes can occur. The clothes you wear under your PPE are equally important. Molten metal –or the arc flash

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Protecting the PSM/RMP covered process (IFC 5001.3.3.6)

Those who follow my posts closely know I am a massive fan of bollards for physically protecting hazardous materials processes. These simple and inexpensive posts have saved my butt over my career more times than I can count, and yet so many still are unaware of their need and requirements. But these bollards are for…...

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Safety Thought of the Week… BENEFITS of a formal SAFETY MANAGEMENT SYSTEM

Growing up in the Process Safety world with OHSA’s PSM and EPA’s RMP standards, I thought everyone had a “Safety Management System.” In school, we learned about OSH Management Systems and all they could do for a business. However, when I started consulting in 2005, I realized that SMSs were elusive in industrial facilities. Even…...

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Hot Work on flammable and combustible liquid storage tanks

In light of the recent HSE video showing a 30′ silo exploding and going airborne for 9 seconds, I thought it might be fitting to offer some guidance on how to SAFELY perform HW on these “used containers.” OSHA’s 1910.252 standard provides no advice other than to say that we must be “absolutely certain” that…...

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IFC and Hot Work Signage

As you know, I am a big fan of the International Fire Code and utilize it more than outdated OSHA standards. One requirement the IFC has that OSHA does not is that “conspicuous signs shall be posted to warn others before they enter the hot work area.” Such signs shall display the following warning:… Membership...

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Combustible Dust and TABLE 5003.1.1(1) Maximum Allowable Quantity (MAQ) per control area of Hazardous Materials posing a Physical Hazard

Combustible Dust was not included in Table 5003.1.1(1) because of the inherent difficulty in establishing a maximum allowable quantity (MAQ) and determining if and when the MAQ had been exceeded. An occupancy with an uncontrolled combustible dust hazard is classified in Group H-2 in accordance with Section 307.4 of the International Building Code (IBC), with…...

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Understanding Table 5704.4.2 – Outdoor liquid storage in closed containers and portable tanks

Table 5704.4.2—Outdoor liquid storage in closed containers and portable tanks (see below) is often referenced when a business wants to store flammable liquids outside the main building. I wanted to take a second to explain the application of that table to those on the EHS team who may not be experienced with the OH Fire…...

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THANKS for all your support!

Due to all the support these past few weeks, I have been able to make another $500 donation to my Alma Mater, Murray State University’s Occupational Safety and Health Program. With this week’s donation, we are over $4,000 for the year. It was the second $500 donation to MSU this year. And yes, I believe

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Cranes and the use of protective helmets

Question: Does 29 CFR 1910.135(a)(1) apply when employees are operating cranes that fall under 29 CFR 1910.179, Overhead and Gantry Cranes, and/or using jib cranes, monorail cranes or fix hoists, for lifting loads indoors and outdoors? Response: OSHA’s Head protection standard at 29 CFR 1910.135(a)(1) requires employers to ensure that each affected employee wears a…...

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Requirements of Mobile Ladder Stand Platforms Used to Access CNC Machines

Scenario: A mobile ladder stand platform with steps will be constructed to access multiple CNC machine tables at a height of 40 inches measured from the floor. Question 1: What are the rise height, tread depth, and width requirements of mobile ladder stand platform steps? Response: The requirements for mobile ladder stand platforms are contained…...

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