Bryan

IFC 2024 changes to hazardous materials storage cabinets

For those who deal with these “hazardous materials storage cabinets,” we have seen some new design requirements over the past couple of code cycles. A lot of codes began requiring “self-closing” doors on these cabinets; however, we can go back to the 2012 edition of the IFC and find this requirement. And now the IFC…...

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EPA RMP & EPCRA citations @ food facility (NH3 & $210K)

Respondent operated a facility that utilizes anhydrous ammonia to provide cooling capabilities to processing, shipping, cooler areas, silos, and chillers for its beef and meat products. On March 30, 2022, EPA performed an inspection of the Facility to evaluate compliance with the Comprehensive Environmental Response, Compensation and Liability Act (“CERCLA”) Section 103, EPCRA Sections 304-312,…...

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More exemptions for Flammable Refrigerants

A few years ago, I warned about the huge push to make flammable refrigerants easier to manage in the name of “global warming.” As a safety professional, this shift is alarming. Never in my career have we considered a burning rate of 10 cm/s as a means to lessen the risk associated with a flammable…...

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Safety Thought of the Week… Internal Consequences

When it comes to safety and health, internal consequences to support the right behavior are terribly important. Remember, external and intrinsic (natural) consequences for safe behaviors are not readily available, and we cannot expect to receive sufficient support (extra consequences) from others to sustain our proactive, safe, and healthy choices. So, we need to talk…...

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EPA RMP & EPCRA citations @ amino acid manufacturing facilities (NH3, Cl2, 37% HCL & $458K w/ $224K SEP)

SPECIAL NOTE: the Cl2 was generated by a truck unloading incident that was a WRONG CHEMICAL-WRONG TANK event (phosphoric acid to sodium hypochlorite) which produced 973 pounds of Cl2. Respondent owns and operates two amino acid manufacturing facilities located near each other (the Facilities). One Facility specializes in food and beverage industries (Foods), and the…...

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Safety Thought of the Week… Views of ‘cause’ limit the effectiveness of defenses against future events.

Post-accident remedies for “human error” are usually predicated on obstructing activities that can “cause” accidents. These end-of-the-chain measures do little to reduce the likelihood of further accidents. In fact, the likelihood of an identical accident is already extraordinarily low because the pattern of latent failures changes constantly. Instead of increasing safety, post-accident remedies usually increase…...

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OSHA publishes “Celebrate Excellence: Recognize Safety and Health Achievements”

Who is this guide for?Professional organizations that play an important leadership role in adopting workplace safety and health strategies. An effective method for improving workplace safety involves creating workplace safety and health recognition programs. This guide will help you build an impactful recognition program. Recognition and appreciation motivate organizations, teams, and individuals to achieve at

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OSHA extends comment period on Heat Injury and Illness Prevention in Outdoor and Indoor WorkSettings

OSHA is extending the period for submitting comments by 15 days until January 14, 2025, to allow stakeholders interested in the NPRM on Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings additional time to review the NPRM and collect information and data necessary for comment. In addition, OSHA is scheduling an informal…...

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Human Factors are what “makes more sense” to us to REDUCE errors and mistake

I am a Toyota Tundra loyalist, but every vehicle has “quirks” that make me scratch my head and wonder, “What were they thinking”? As a side note, I drove many rental vehicles when traveling a lot at the peak of my consulting. It would take me 1-2 minutes to get my seat and mirrors set;…...

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Eight (8) workers die inside refrigerated truck with “dry ice” (China)

The report indicated that the driver of the refrigerated truck had poor safety and legal awareness. He allowed eight female workers to ride in the truck, which carried packaged beef with dry ice. The dry ice sublimed into carbon dioxide gas, which rapidly filled the confined space inside the truck…. Membership Required You must be...

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NIOSH vs OSHA’s Hiearchy of Controls

Which model do you prefer? The Classic Inverted PyramidThe conventional representation of the hierarchy of controls is an inverted pyramid structure conveying the prioritization of strategies. Current versions orient the pyramid differently, depending on the agency or application of the controls. The clearest conflict in visual representation between the inverted and typical pyramid is found

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