Bryan

Safety Thought of the Week… BENEFITS of a formal SAFETY MANAGEMENT SYSTEM

Growing up in the Process Safety world with OHSA’s PSM and EPA’s RMP standards, I thought everyone had a “Safety Management System.” In school, we learned about OSH Management Systems and all they could do for a business. However, when I started consulting in 2005, I realized that SMSs were elusive in industrial facilities. Even […]

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Hot Work on flammable and combustible liquid storage tanks

In light of the recent HSE video showing a 30′ silo exploding and going airborne for 9 seconds, I thought it might be fitting to offer some guidance on how to SAFELY perform HW on these “used containers.” OSHA’s 1910.252 standard provides no advice other than to say that we must be “absolutely certain” that…...

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IFC and Hot Work Signage

As you know, I am a big fan of the International Fire Code and utilize it more than outdated OSHA standards. One requirement the IFC has that OSHA does not is that “conspicuous signs shall be posted to warn others before they enter the hot work area.” Such signs shall display the following warning:… Membership...

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Combustible Dust and TABLE 5003.1.1(1) Maximum Allowable Quantity (MAQ) per control area of Hazardous Materials posing a Physical Hazard

Combustible Dust was not included in Table 5003.1.1(1) because of the inherent difficulty in establishing a maximum allowable quantity (MAQ) and determining if and when the MAQ had been exceeded. An occupancy with an uncontrolled combustible dust hazard is classified in Group H-2 in accordance with Section 307.4 of the International Building Code (IBC), with…...

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Understanding Table 5704.4.2 – Outdoor liquid storage in closed containers and portable tanks

Table 5704.4.2—Outdoor liquid storage in closed containers and portable tanks (see below) is often referenced when a business wants to store flammable liquids outside the main building. I wanted to take a second to explain the application of that table to those on the EHS team who may not be experienced with the OH Fire…...

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THANKS for all your support!

Due to all the support these past few weeks, I have been able to make another $500 donation to my Alma Mater, Murray State University’s Occupational Safety and Health Program. With this week’s donation, we are over $4,000 for the year. It was the second $500 donation to MSU this year. And yes, I believe

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Cranes and the use of protective helmets

Question: Does 29 CFR 1910.135(a)(1) apply when employees are operating cranes that fall under 29 CFR 1910.179, Overhead and Gantry Cranes, and/or using jib cranes, monorail cranes or fix hoists, for lifting loads indoors and outdoors? Response: OSHA’s Head protection standard at 29 CFR 1910.135(a)(1) requires employers to ensure that each affected employee wears a…...

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Requirements of Mobile Ladder Stand Platforms Used to Access CNC Machines

Scenario: A mobile ladder stand platform with steps will be constructed to access multiple CNC machine tables at a height of 40 inches measured from the floor. Question 1: What are the rise height, tread depth, and width requirements of mobile ladder stand platform steps? Response: The requirements for mobile ladder stand platforms are contained…...

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Fall Protection on low slope roofs

An HVAC technician uses a portable ladder to access a low-slope roof 12 feet high. The ladder is secured to the building and placed at a 4/1 angle. The side rails of the ladder extend three feet above the roof landing. The HVAC unit to be worked on is 25 feet from the roof’s edge…....

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Applicability of OSHA’s definition of oxygen-deficient atmosphere to Air Force facilities

Background: You state that as a Senior Mechanical Engineer for HVAC systems in Air Force facilities, you are responsible for setting design standards for mechanical systems in the facilities (primarily office buildings but also childcare, emergency operations, & dormitory-type buildings). In this capacity, you sometimes use HVAC systems that may expose facility occupants to the…...

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Hot Work on “used containers”, including process vessels, results in two workers receiving life altering injuries

On 20 September 2017, two employees of were using a grinder to cut and replace pipework at the top of an 11-metre (40’) high metal tank containing waste slurry. They were not using harnesses. Sparks from the grinder ignited flammable gasses causing the tank to explode. The slurry vessel was airborne for 9 seconds and…...

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