Can we deny an employee a specific job if they refuse to be medically qualified for respirator use?
Employees who refuse to undergo a medical evaluation cannot be assigned to work in areas where they are required to wear a respirator.
Do you consider “Fit Testing” records to be “medical records” and off-limits to a 2nd/3rd-party auditor?
In the past 12-months I have been told by three (3) organizations that I can not audit the fit testing records because they are “personal medical records”. After some time, I finally convinced their legal team that fit tests are not medical records, and I was then allowed to audit the records. And of course,
Medical Evals for Respiratory Protection (RP) standard do NOT qualify as the HAZWOPER Medical Surveillance
The Respiratory Protection (RP) standard medical questionnaire for 1910.134 will NOT satisfy the HAZWOPER medical surveillance requirement. The intent and requirements for medical surveillance under HAZWOPER are very different from those required by the Respiratory Protection standard. The intent of the HAZWOPER medical surveillance requirements are two-fold:
Fireproofing piping supports
Fireproofing piping supports — specifically the application of Passive Fire Protection (PFP)— is a critical mitigation strategy designed to prevent the structural collapse of pipe racks during a flammable liquid fire. In most state fire codes and the IFC, flammable liquid piping supports inside a secondary containment are REQUIRED to be protected from the effects
Does federal OSHA require a “swing gate” at a vertical point of ladder access at the edge of a walking/working surface?
The simple answer is yes. Federal OSHA requires either a self-closing swing gate or an offset barrier at the point of access where a fixed ladder meets the unprotected edge of a walking-working surface. While the regulatory text in Subpart D sometimes causes confusion by referring to these access points as “holes,” OSHA consistently enforces
PHMSA issues guidance on NH3 Nurse Tank Non-Destructive Testing
In February 2024, the Federal Motor Carrier Safety Administration (FMCSA) and PHMSA issued a safety advisory to provide notice of the possibility of catastrophic failure of nurse tanks. This notice focused on nurse tanks manufactured from January 1, 2007, through December 31, 2011, by American Welding and Tank (AWT) at its Fremont, Ohio plant. Nurse
Preventing Hearing Loss Caused by Chemical Exposures (Ototoxicity)
Think about… when we are working around chemicals, we typically look at forms of exposure such as inhalation, absorption through the skin, etc., and we wear the appropriate PPE. For example, we may wear a full-face respirator, gloves, and an apron to protect against splash and vapors. But there is one organ that is normally
How detailed should our means to verify ZES be?
This is a pet peeve of mine: DETAILS MATTER in safety procedures and safe work practices. One thing we commonly find is some very generic language in LOTO procedures for how to verify each energy source has been isolated and is at a Zero Energy State (ZES). For example, you’re performing a “periodic inspection,” and
OSHA cites big rig parts distributor for confined space fatality (asphyxiation), safety hazards after worker fatality at the company’s Corpus Christi facility
OSHA has cited a big rig parts distributor for 16 serious safety violations after an investigation into a worker fatality found the company exposed workers to confined space and other safety hazards. OSHA initiated an inspection on Jan. 7, 2026, after an employee asphyxiated while inspecting a tanker trailer. OSHA cited the company for 16
The double H2S fatality event at a Kraft Mill is the classic anatomy of an accident – CSB Issues Woodland Pulp Investigation Update
This is WHY we need the CSB! We would never get this type of analysis from an OSHA investigation/report. No offense to my friends at OSHA, its just this type of analysis and passing on the critical information is not part of their charter. Today, the U.S. Chemical Safety and Hazard Investigation Board (CSB) released
Pressure testing piping and the connected vessels
Every once in a while, I come across a process design that leads to code issues down the road. This usually occurs with small pressure vessels (e.g., less than 5 cubic ft) that fall outside the scope of ASME Section VIII and also fall outside the scope of being a “confined space” (e.g., too small
Would the risk management program regulations cover the loading and unloading of transportation containers?
The definition of stationary source includes transportation containers used for storage not incident to transportation and transportation containers connected to equipment at a stationary source for loading or unloading (40 CFR Section 68.3). In a January 6, 1998 final rule (63 FR 640), EPA clarified that if a container remains attached to the motive power that