Someone requested OSHA to address the growing field of virtual reality safety and health training. Their letter constitutes OSHA’s interpretation ONLY of the requirements herein, and may not be applicable to any questions not delineated in the original correspondence. Your paraphrased questions and our responses follow. Question: We have been told online, commercially available, training […]
OSHA’s latest position on testing electrical gloves is very enlightening! For example, even if the gloves are simply electrically tested and then returned to storage, OSHA regards the gloves as being issued for use! This is a new one on me, but in their latest LOI they discuss the following scenario: gloves got tested on
No, the employer is not required to include findings and recommendations from the facility siting study report in the same PHA worksheet or recommendations log to comply with 29 CFR § 1910.119(e)(5) and 29 CFR § 1910.119(e)(7).
As I always say, we can not discuss MOC and PSSR as if they are separate systems… they go hand in hand 99% of the time. That is what I want to discuss: how a PSSR requirement defines how we manage our MOC system. We have discussed many times there are ONLY TWO (2) occasions
At approximately 4:00 a.m. on March 29, 2020, an employee was installing a blind on a flange on a reactor. Then, the probe stem fell inside of the reactor, and the employee tried to fish it out. Using a ladder, the employee went inside the reactor that was NOT cleared for entry because the reactor
Buckle up buttercup… the political winds in DC are shifting and with this comes “opportunities” – man how I hate politics! For those of you who may have thought that the RMP Amendments from the final year of the President Obama administration were long gone – THINK AGAIN! On Friday (12/4/20), the U.S. Court of
On the plate heat exchanger, a machined nut backed off on the flange bolt that holds the gasket in place. This caused part of the gasket to blow out resulting in ammonia (NH3) to leak into the machine room. The machinery room alarm was activated. Upon inspection, the following failures were found:
The word “potential” is defined by Merriam-Webster as: existing in possibility : capable of development into actuality In OSHA’s PRCS standards (both 1910 and 1926 versions) it uses the word “potential” when talking about atmospheric hazards; especially when we are talking about RECLASSIFYING a PRCS to a NON-PRCS using 1910.146(c)(7) or 1926.1203(g) 1926.1203(g)(1) If the permit
This draft guidance document is intended to clarify to the public regarding existing pipeline safety standards. The contents of this document do not have the force and effect of law and are not meant to bind the public in any way, but pipeline operators must comply with the underlying safety standards. (emphasis by me)
Most facilities will have a piece of equipment that is so large and complex that it will entail isolating many sources of all types of energy in order to get the entire system to a zero energy state (ZES). But what do we do when we have a task that involves exposure to only one
The 2021 edition of the International Fire ode (IFC) basically re-wrote the entire chapter on Combustible dust; which is a major improvement from the 2018 edition. Here are the highlights from the 2021 IFC, Chapter 22 – Combustible Dust-Producing Operations…
In the recently released Internation Fire Code (IFC) 2021 edition, the newly designated Section 608 – Mechanical Refrigeration, the code references IIAR 2, 6, 7, 8, and 9 when the refrigerant used is anhydrous ammonia (NH3). The 2021 edition still has many of the long-time requirements that will apply to NH3 systems, such as “emergency
