2017 Photo of the Week #35 (did you know that @ 18 years old OSHA no longer requires LOTO)
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2017 Video of the Week #35 (Gravity is an energy source!)
I have heard of this happening several times off the span of my career, but this is the first time I have seen it. I will also add that “gravity” is the most often overlooked/ignored energy source when it comes to LOTO. With “electrical” being the most recognized energy source, somehow the one source that…...
BLEVE vs. HIT
Once again I turn to the professionals up North to provide us with some great information. Transport Canada has once again done an excellent job explaining the difference between a Boiling Liquid Expanding Vapor Explosion (BLEVE) and a Heat-Induced Tear (HIT) type explosion. So often when we see the large fireball, we will call the…...
Clarifying the “continuous employee occupancy” confined space definition
In both their General Industry and Construction Confined Space Standards, one of OSHA’s criteria for a “Confined Space” is that the space is “not designed for continuous employee occupancy.” These six (6) words seem to cause much confusion on both ends of the CS debate. I have seen it misused to claim a space is…...
Are you confident in your Hot Work Program, Permit, and Training?
In the process safety arena, OSHA’s PSM Standard (and EPA’s RMP rule) made it official… doing “hot work” in/on/adjacent to the “covered process(s)” required a WRITTEN PERMIT. Before PSM/RMP, OSHA only “preferred” the permission to perform Hot Work be in written form. OSHA PSM (and RMP)intent was to require employers to control, in a consistent…...
Understanding Human Error (Parts 1-5)
One of the best books in my career is the first edition of “Field Guide to Human Error Investigations” (pdf) by Dr. Sidney Dekker (Ph.D. in Cognitive Systems Engineering); which then became “The Field Guide to Understanding Human Error” (2nd Edition). Those of you in the Process Safety arena have some baseline knowledge of “Human…...
2017 Video of the Week #34 (LOTO/Guarding Failure – GRAPHIC FATALITY)
WARNING! The video contains graphic images of a worker’s death. Worker is pulled into a paper machine calendar as he is applying a label. As can be seen, by the video, the RPMs were low, but the torque of the machine was too much for him. His foot hits the E-stop bar but it was too late…. Membership...
2017 Photo of the Week #34 (Hotwork Shocker)
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Developing a Safety Culture is like raising kids
With the sad revelations coming out of the Slag Tank catastrophe and having spent time with my Dad a couple of weekends ago A thought just popped in my head… as a child my parents were constantly saying “I don’t care what Johnny is doing” and “if Johnny jumped off a bridge would you?”…...
A PERFECT example of Inventory Management and Inherently Safe Design (CL2 & $220K)
Here we have a darn near perfect example as to why OSHA/EPA are now asking businesses with PSM/RMP covered process to “justify” their “maximum intended inventory(s)” of their Highly Hazardous Chemicals (HHC)/Extremely Hazardous Substances (EHS). The business had, at the time of the EPA inspection four (4) 1-ton cylinders of Chlorine in the same room…...
OSHA’s position on “Swing Gates” and fixed ladders
For years, OSHA had taken a position on when/where “swing gates” were actually required and that position was that it did NOT apply to fixed ladders on the edge of a platform. Then in 2009 they officially stated their enforcement position in a Regional Memo that DID include ladderway opening on the edge of a…...
Georgia’s Insurance & Safety Fire Commission issues Pressure Vessel Code violations following Nitrogen Fatality ($302K)
NOTE: This case, as unfortunate as it is, stands in a very small group of State Fire Code violations, and in my memory stands atop of the pile @ $302,500. It is rare for a state to issue code violations and even more rare for the dollar amount to be so high. The one thing…...