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The SHELL Model

The SHELL Model is a conceptual tool used to analyze the interaction of multiple system components.  The SHELL Model contains the following four (4) components: SOFTWARE (S): procedures, training, support, etc. HARDWARE (H): machines and equipment ENVIRONMENT (E): the working environment in which the rest of the L-H-S system must function and LIVEWARE (L): humans…...

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The circle of safe(ty)

One of my favorite movies is “Meet the Parents” and in this movie, the bride’s to-be dad, Jack, had his “circle of trust”.   Well not to poke fun at the concept, we also have the “circle of safety”.  It is core in each and every one of us.  When we feel like we can trust…...

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Respiratory protection against COVID-19 for employees with religiously mandated facial hair (OSHA LOI)

Generally, you asked OSHA to clarify whether loose-fitting powered air-purifying respirators (PAPRs) are a permissible alternative to N95 respirators where respiratory protection is required to protect workers from exposure to SARS-CoV-2, the virus that causes COVID-19. Additionally, you asked OSHA to clarify the interplay between the Respiratory Protection Standard and other laws that may require…...

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The COVID ETS is not like 1910.1030!

It seems there is a faction of safety professionals who want to claim that if OSHA’s blood-borne pathogens standard is “legal”, then so would the COVID ETS.  But these two standards are nothing alike.  For example, OSHA defined “occupational exposure” in 1910.1030 as: Occupational Exposure means reasonably anticipated skin, eye, mucous membrane, or parenteral contact…...

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“COLD” BLEVE caught on tape

Back in June of last year (2020), the city of Wenling in China experienced a tragedy that involved a COLD BLEVE of a flammable liquified pressurized gas tanker truck and a subsequent explosion killing 18 people.  We have dashcam footage of the COLD BLEVE and it is “textbook” footage of such an event – we…...

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Safety Management in 2022 – Leadership without an SMS?

Do you agree with this “safety leadership” quote?   “A system or a procedure never achieved anything, it is people being committed to implementing the system that achieves the performance needed.”   It comes from the Safety Leadership Group (SLG) of which I am a fan…. Membership Required You must be a member to access...

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EPA issues RMP citations @ cellophane manufacturing facility (CS2 & $97K)

Respondent owns and operates a cellophane manufacturing facility that uses Carbon disulfide in excess of the 20,000 pounds RMP TQ. On or about September 11 and 12,2019, EPA conducted an inspection of Respondent’s Facility to determine compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68. From the time Respondent first had onsite…...

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What it means to be a safety leader rather than a safey manager or engineer

I have a friend that I respect immensely and I think he may be one of the most intelligent people I interact with.  He is a huge fan of Jordan Peterson and he is always sharing books, podcasts, and videos with Dr. Peterson.  Oftentimes, his podcasts and videos are beyond my ability to fully comprehend…...

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Safety is a selfish act

The title may sound bad, but in reality, when safety becomes a selfish act we have actually established the culture that we have all dreamed of.  Safety is not something we do for a government agency, heck it is not even something we should be doing for the company.  Safety is something we do FIRST…...

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2021 OSHA HAZWOPER (1910.120) activity by Industry Sectors

Here is a look at OSHA’s HAZWOPER compliance activity in 2021 (October 2020 – September 2021). As you can see, OSHA did 24 HAZWOPER inspections and issued 48 citations for a total of $156,418 in fines. This is the SETTLED amount and NOT the initial citations. Here is a quick breakdown of activity:… Membership Required You...

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2021 OSHA PSM activity by Industry Sectors

Here is a look at OSHA’s Process Safety Management (PSM) activity in 2021 (October 2020 – September 2021).  As you can see, OSHA did 36 PSM inspections and issued 217 citations for a total of $2,194,474 in fines.  This is the SETTLED amount and NOT the initial citations.  Here is a quick breakdown of activity:… Membership...

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