A few years ago I was asked to participate in a hazard assessment for a manufacturer who wanted to review the procedure for hydrogen-powered vehicles to be freed of hydrogen gas. I got the feeling very early into this hazard assessment that those in the room knew about an event of some type, but wanted […]
This is an EXCELLENT 1-page Alert on the hazards of “Splash filling” non-conductive flammable liquids. SPEED MATTERS, as does process design! To read more on handling non-conductive flammable liquids CLICK HERE
On January 17, 2020, EPA performed an inspection of the Facility pursuant to Section 112(r) of the CAA, Sections 304-312 of EPCRA, and Section 103 of the Comprehensive Environmental Response, Compensation, and Liability Act. Based upon the information gathered during this inspection and subsequent investigation, EPA asserts that Respondent violated certain provisions of the CAA
So in my previous post, we covered the SIZE of the EXIT signs and in this post, I want to cover the “illumination” requirements of these EXIT signs. Simply stated, OSHA and the IBC require the face of the sign to be illuminated to at least 5-foot candles or 54 Lux at ALL TIMES. Which
Earlier this year we were asked to assist in a site assessment after a tragic accident. During this assessment, it was hard not to notice all of the brand new exit signs the facility had put up (i.e. stuck up as they were stickers). These signs were super clean as compared to the rest of
Be careful, experience shows that most who read this will find it offensive… Meet “Ed”, he is just a maintenance worker I meet in 1994. My first impressions of Ed were he was safe (i.e. always followed the safe work practices, always had on his PPE properly, etc.) based on my personal observations. One day
Respondent owns and operates a chemical manufacturing facility that has a chlorine (Cl2) process at the stationary source in excess of the applicable threshold quantity. The chlorine-covered process is subject to the “Program 3” requirements of the Risk Management Plan (RMP) regulations and must, among other things, to comply with the Program 3 Prevention Program
I love the Line Break and Equipment Opening (LEO) SWP because it is one of the most hazardous tasks a worker will perform within a covered process AND the fact that there is no OSHA standard dictating how a business manages these risks. This lack of “OSHA Control” spoon-feeding us safety requirements causes most management
This case involves a citation regarding the “grandfather training clause” found in both OSHA’s PSM and EPA’s RMP. I have never seen it cited before, but I take my hat off to the EPA inspector for peeling that onion! Basically, this food facility had two (2) employees who had been hired in January and September
See if this sounds all too familiar… three (3) workers remove a manhole cover to a sanitary sewer to check for water and blockage. Unable to see anything, Employee #1 climbs down into the sewer to look for problems. A co-worker working nearby sees Employees #2 and #3 enter the manhole and comes over to
Line Breaking and Equipment Opening (LEO) hazards are oftentimes not well recognized or respected, even in PSM/RMP-covered processes. Once we are removed from a “covered process,” the lack of recognition and lack of respect only increases. But in my career, some of the more serious accidents involving LEO on lines/equipment did NOT involve processes covered
Please note this citation was issued as a General Duty Clause (GDC) citation by a State OSHA Plan and the incident was not a PSM/RMP incident (at least OSHA did not cite .119). The practice at issue is one that is done routinely in just about all companies and on just about every type of
