WHY OIG CONDUCTED THE AUDIT The Occupational Safety and Health Administration (OSHA) is responsible for ensuring safe and healthful working conditions for 130 million workers employed at more than 8 million worksites. It does so by setting and enforcing standards and by providing training, outreach, education, and assistance to employers and employees. The COVID-19 pandemic…...
The Chemical Facility Anti-Terrorism Standards (CFATS) program requires high-risk facilities to ensure security measures are in place to reduce the risk of more than 300 chemicals of interest (COI) being weaponized. High-risk facilities are assigned to one of four (4) risk-based tiers and must develop a security plan meeting the 18 Risk-Based Performance Standards (RBPS). …...
MINE FATALITY – On October 7, 2022, a mechanic was fatally injured when engulfed in the material after entering an air separator to clear a blockage. Best Practices… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
Last week I wrote about how either distance or a barrier is necessary to CONTROL hazards. OSHA’s made a great case in 2020, explaining how the separation distances in 1910.110 is a PASSIVE MITIGATION measure. (emphasis by me) OSHA concludes that NFPA 58 (2017), Sections 6.28.2 and 6.28.3, do not provide an equivalent level of…...
Recently a trade organization issued a guide on working in Permit Required Confined Spaces specific to their industry. The organization took a sentence from NFPA’s Guide on Confined Spaces (NFPA 350) and used it as justification to circumvent OSHA’s minimum standard on entry into PRCSs (1910.146 and 1926.1201-.1213). l have received over a dozen questions…...
As stated in REGO’s Warning Document… Simply retesting pressure relief valves manufactured by RegO that have been in service for several years to confirm conformance with start-to-discharge and reseal ranges does NOT guarantee that the valve is suitable for continued service. Or that the valve will perform as designed at nominal pressures or in emergency…...
“Relief valves should be inspected each time the container is filled but no less than once a year. If there is any doubt about the condition of the relief valve, it must be replaced.” Major Factors to determine the “Life” of Relief Valves include: Water/Ice Accumulation Corrosion Dirt – Debris Damage Normal Aging Eye protection…...
The old debate has been settled by the largest provider of LEVEL A suits. Many organizations store their emergency response gear in a trailer that is parked (usually) outside on the property. Although OSHA does not mention this level of detail, the manufacturer has now established the maximum temperature at which their suits may be…...
In a recent discussion regarding an accident with a Fuel-Oxy Torch system, I had some discussions about the layers of protection and the Prevent-Protect-Mitigate safety model using the Hierarchy of Controls (Elimination, Substitution, Engineering Controls, Administrative Controls, and PPE). The event did NOT involve a flash-back, but I used the flash-back requirements to demonstrate the…...
On February 19, 2022, Employee #1 took apart an active heat exchanger. While doing this, 419 pounds of ammonia were released, causing upper body burns to the employee. The employee was hospitalized for treatment…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
At 3:10 p.m. on February 2, 2022, an employee, 26, was performing maintenance on a System Applicator. The employee began the ammonia bleeding procedure wearing safety glasses and rubber gloves. After approximately 20 to 30 minutes, the employee no longer heard a whistling sound and believed that the system was completely bled out. When the…...
It seems the games may never end with HFO-1234yf and it’s designation as a Highly Hazardous Chemical (HHC) within the Process Safety Management Standard. A friend of a friend in the automobile manufacturing industry contacted me about their use of this new refrigerant. The friend/client shared all of my previous articles explaining how HFO-1234yf is…...
