EPA recently issued two citations to a juice processing facility for failing to comply with the amended requirements in 40 C.F.R. § 68.93(a) & (c). On March 21, 2022, an incident at the ammonia refrigeration facility resulted in an accidental release (the “Incident “). Pursuant to Section 114 of the CAA, 42 U.S.C. § 7414,…...
Respondent has a refining process meeting the definition of “process”, as defined by 40 C.F.R. § 68.3. Methane, ethane, propane, pentane, propylene, hydrogen, butane, hydrogen sulfide, and ammonia are each a “regulated substance” pursuant to 40 C.F.R. § 68.3. The threshold quantity for methane, ethane, propane, pentane, propylene, hydrogen, butane, hydrogen · sulfide, and ammonia…...
Several organizational characteristics can feed organizational silence: Managerial illusions: managers can believe that the situation is under control simply because of the number of procedures. They can also believe that failure to follow a procedure is the only possible mechanism that can produce accidents. This discourages feedback about situations where procedures are difficult, time-consuming, or…...
It is commonly admitted that the great majority of industrial accidents are caused directly by specific unsafe acts of persons or exposure to specific mechanical or physical hazards. It is agreed that these causes and the accidents that they create interfere seriously with the quality, volume, and cost of production and are of a preventable…...
The client this week had such an eye-opening experience with the risk assessment yesterday; they were all early this morning and had written out their homework assignment for the night! We took their loading docks and did the OSH version of LOPA called a Hierarchal Analysis around workers being crushed by a trailer at the…...
As safety pros return to work this week from the annual ASSP conference last week, their excitement and enthusiasm will either blossom or bottom out. So many new techniques are being pushed in the safety arena these days, and many safety pros and management personnel are grasping for whatever it takes to turn their safety…...
During offshore energy operations, a worker was recently injured while attempting to install a hydraulic line on a pipe-handling machine. The worker determined that the combination wrench on hand was too long for this particular use and attempted to manually alter the tool by placing the wrench into a vice to shorten the length using…...
Thanks to Ross W Skaggs, CSP (ret) , for another pic – follow him @ LinkedIn for more. Today’s pic will make you scratch your head and maybe wonder how that could happen. “No Parking” signs may be one of society’s most widely used signs. They convey a simple directive, yet can you guess the…...
We are all familiar with OSHA’s LOTO Periodic Inspection requirements (1910.147(c)(6)). It is a topic of great debate, still in the Year 2023. But there is a serious, I say it is a fatal flaw in the periodic inspection process. It is common for this activity to be performed by managers/supervisors who are authorized in…...
When people say, “safety is just common sense,” I wish we could slap them. Working for a client in KY, I have identified so much that is different between their state plan and the federal OSHA requirements. Some of the differences just do not make sense and I am sure there are some political forces…...
As with some state plans, KY-OSHA has some standards that are more in-depth than the federal version. Although, a couple of years ago, the KY legislature passed a bill that restricts KY-OSHA from adopting any standards that are more stringent than federal OSHA. But for now, KY-OSHA’s 1st Aid standard goes much further than federal…...
Where an employee is confronted with a choice between not performing assigned tasks or being subjected to death or serious injury arising from a dangerous condition at the workplace, such employee may refuse in good faith to expose himself/herself to the dangerous condition. The condition causing the employee’s apprehension of death or injury must be…...
