Several years back, I worked with an organization that had an in-house Operational Testing program with a really catchy name. I actually loved the name, but as I learned more about the process, it was simply a catchy name for a very bad process. It was an attempt by a business to have BOTH a […]
Recently, I had the opportunity to help a client gain the full picture of what has to be done regarding the BULK TRANSFER hoses to unload their HHC/EHS from Tanker Trucks/ISO Containers and Railcars. Now, before we get into the specifics, I know a number of folks will fall back on the compliance position that
Last week, David Ayers, Ph.D., CSP, CHMM, and I had a nice chat regarding LOTO and Complex Processes, and one of the areas associated with these LOTOs is the “evacuation” of the HAZMAT within the process/system. We did not have enough time for me to get deep into the weeds on this aspect of isolating
In our PSM/RMP and OSH audits, we always spend more time on the Life Safety Standards, such as PRCS, LOTO, LEO, Respiratory Protection, etc. One of the most common errors we find in these audits is the lack of training for the attendants. It’s not that they are not meeting 1910.146(i)(1) – 1910.146(i)(10) training obligations;
An explosion at a large outdoor oil storage tank at Korea National Oil Corporation Pipeline’s Yeongnam branch is preliminarily attributed to static electricity generated during a petroleum component verification process. The incident occurred at a large-scale oil storage facility housing 12 to 14 tanks, raising concerns that it could have escalated into a major disaster.
We see this often, handling, storing, and processing a Class IIIA flammable liquid, and about half will classify the area, and the other half do not. So who is right? Here is my take on the matter as I work thru the risk analysis…
OSHA has cited a petroleum tank services contractor for exposing workers to chemical and respiratory hazards after an employee was fatally exposed to benzene and toluene when they entered a fuel storage tank in July 2025. Investigators cited the company with 12 serious violations for failing to develop and implement a written permit-required space entry
Question 1: To what extent does OSHA’s Respiratory Protection standard, at 29 CFR § 1910.134(e), require that the PLHCP’s medical evaluation for respirator use include consideration of factors beyond respiratory protection that affect fitness to safely perform the expected job tasks while wearing a respirator? Question 2: Is there a reasonable expectation that the employer
The Safety Champions Program (SCP) assists employers in developing and implementing a robust safety and health program (SHP). The main goal of safety and health programs is to prevent workplace injuries, illnesses, and deaths, as well as the suffering and financial hardship these events can cause for workers, their families, and employers. The SCP is
OSHA has cited a Florida plumbing, heating, and air conditioning contractor for exposing workers to struck-by hazards after an employee suffered a fatal injury at a Bal Harbor Shops worksite in August 2025. OSHA found that on Aug. 28, 2025, a pipefitter installing a new air-conditioning system for a mall expansion construction project was fatally
Hearing protector fit testing (HPFT) is a critical advancement in workplace hearing conservation and is recognized as a best practice (OSHA et al., 2008; OSHA, 2017). HPFT is not required under OSHA’s Occupational Noise Exposure standards (29 CFR 1910.95; 29 CFR 1926.52), but can be a valuable training tool for workers. HPFT measures the amount
I have written about this incident a couple of times, as it is full of learning opportunities. The biggest of which is the practice of REDUCING PPE after the initial opening was uneventful, and we have “verified” our positive means of isolation is holding. This is a common practice for long-duration jobs and plays a
