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Secondary Container Labeling, OSHA, and NFPA 704 Diamond

A lot has been said on LinkedIn about secondary container labeling, and at least seven (7) posts were absolutely wrong. Those posts have been shared more than 400 times; I wish I knew how many views. Many people agreed with the original posters that secondary containers had to be labeled the same as shipped containers…....

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When an entrant is at an LEL, they are usually way beyond the PEL/TLV/STEL

When we talk about Lower Explosive Limits, most people imagine a flash-fire hazard (as they should!). But when a worker is in a flammable atmosphere, they are also being WAY OVER EXPOSED. Take the following OSHA PRCS fatality case, where the worker died from being overexposed to organic vapors. The Atlantic City Fire Department Confined…...

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Is your facility “car-sealing” OPEN it’s EW/SS isolation valves?

Here is what ANSI 358 says: (emphasis by me) 5.1.6 Eyewashes shall be capable of delivering flushing fluid to the eyes not less than 1.5 liters per minute (0.4 gpm) for 15 minutes. If shut off valves are installed in the supply line for maintenance purposes, provisions shall be made to prevent unauthorized shut off…....

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Manual addition of powders to a flammable atmosphere (NFPA 77)

As I noted in 2007, the #1 cause of process vessel deflagrations is the manual additions of powders to process vessels which have a flammable atmosphere. NFPA 77 covers this hazard with several solutions, yet many facilities are either not aware of these risks and solutions or simply have their head buried regarding these catastrohic…...

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“Switch Loading” injures worker

The definition of “switch loading: Switch loading is the hazardous practice of loading a low-vapor-pressure product (such as diesel or heating oil) into a tank compartment that previously contained a high-vapor-pressure, flammable product (such as gasoline) without first cleaning it. This creates a high risk of static electricity generation and explosion, as residual vapors can…...

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Routine Line/Equipment Opening MUST be done via SOP or SWP

This is a classic case of a “routine opening” within a PSM/RMP-covered process that turned fatal for an operator. ALL openings of a process containing a hazardous energy source, PSM/RMP or NOT, can be some of the most hazardous tasks we can ask personnel to perform. At approximately 1:00 a.m. on August 14, 2011, Employee…...

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PRCS Fatality @ Winery (HAZ ATM -N2)

An accident at a Winery in California may have caused the death of a 20-year-old winery worker on Friday, Jan. 8. He was found inside a 1,500-gallon tank and apparently died from asphyxiation. “We’re still trying to figure out exactly what happened,” said the winery president. “He was a wonderful person, a fabulous worker, and…...

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New construction is using OLD Designs (Ladders & Stairs)

In the past several years, I have had the pleasure of working on some fascinating start-ups. But the one thing they all have in common is that their ladders do not meet the new ladder standard, 1910.23. Ladders still have cages, not a fall arrest system, etc. The other thing that drives me crazy is…...

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Coast Guard investigating fatal confined space incident

Of the four crewmembers involved in the incident, two are deceased. The other two crewmembers are reported to be in stable condition. Watchstanders at the Coast Guard Sector Southeast Alaska command center in Juneau received a mayday call at 9:14 a.m. Sunday that the crew of the tug vessel Chukchi Sea lost contact with four…...

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EPA RMP Citations @ sulfuric acid manufacturer (NH3, CS2, CH 3SH, C3H6, C2S5SH & $40K)

Respondent has six regulated substances present at the Facility:anhydrous ammonia, carbon disulfide, 2-butene, 3-butadiene, propylene, and ethyl mercaptan. Respondent’s Facility manufactures sulfuric acid and regenerates spent sulfuric acid, meeting the definition of “process”, as defined by 40 C.F.R. § 68.3. Respondent has a quantity of the aforementioned chemicals greater than the threshold. ALLEGED VIOLATIONS TrainingOf…...

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EPA RMP GDC citations @ pool supply business (Ca(ClO)2 & $37K

On September 25, 2024, an incident at the Facility resulted in an accidental release. EPA sent an informal questionnaire to the respondent on April 17, 2025. Respondent provided documentation and information on June 9, 2025. Based on the response provided on June 9, 2025, EPA conducted an investigation of the Facility to determine Respondent’s compliance…...

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