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Its not the product that matters, its the free fall that creates the static

I hope that in today’s workplaces, everyone knows we do NOT “splash fill” flammable liquids. However, this simple fact is often overlooked or unknown when adding a non-flammable solution to a flammable one. Its not the product that matters, it’s the free fall that creates the static within the flammable atmosphere…. Membership Required You must...

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Hazards of deluge foam systems and ignoring the pre-discharge alarm

At 1:30 p.m. on August 7, 2022, a 55-year-old production supervisor was working in his office when the deluge system pre-discharge alarm activated. Approximately 30 seconds after the audible alarm engaged, the foam generators activated and began dispensing 2.2% high-expansion foam. The employee attempted to exit his office to reach a safe point, but he…...

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OSHA launches the Safety Champions Program

The Safety Champions Program is a new initiative that helps employers develop and implement effective safety and health programs. The main goal of safety and health programs is to prevent workplace injuries, illnesses, and deaths. The Program incorporates the seven (7) core elements of Recommended Practices for Safety and Health Programs: The Safety Champion Program…...

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EPA RMP Citations @ food plant (NH3 & $37K)

Respondent is the owner and operator of a facility. On September 1, 2024, an incident at the Facility resulted in an accidental release. EPA requested follow-up information, and Respondent provided a response on May 27, 2025, regarding the Incident and Respondent’s compliance with Section 112(r) ofthe CAA and 40 C.F.R. Part 68. Based on the…...

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Managing inventory of our HHC/EHS during emergencies

I ALWAYS encourage clients to be able to MANAGE their inventory when something goes wrong. Many have heeded my advice, and when they have a leak on a tank, they simply transfer the hazardous material to their “emergency tank,” or they have set their maximum levels in other tanks so they have spare capacity on…...

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Would you claim you could drive a vehicle safely if I covered up the dashboard?

An SMS needs a feedback loop! The data from that feedback loop needs to be VERIFIED and VALIDATED as accurate BEFORE it is used to make decisions within the SMS. Just imagine driving your vehicle with NO FEEDBACK. No speedometer, no engine temp, no blinker feedback, no RPMs, NOTHING. You’re just driving, maybe relying on…...

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Catastrophic low-water steam explosion (Boiler @ Food Plant 2021)

Damage description: Significant damage to the boiler room and all adjoining walls/rooms and area. Extensive damage to the west wall of the plant on Acton Pl. through the street. Damage was also noted to the adjacent building located at 390 E. King St. This complex housed several retail establishments. Damage was also noted to several…...

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Defining and Quantifying “incidental releases” and ones requiring an “emergency response”

This is a perfect (and sad) example of why releases of hazardous materials need to be DEFINED and QUANTIFIED so that personnel know their LIMITATIONS in responding to said releases. This exercise is part of our PRE-PLANNING, starting with using the Tier II forms we submit each year. Just understand, the Tier II forms are…...

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Isolating piping passing through a PRCS (OSHA LOI)

Well, it’s not often that I disagree with the OSHA technical team that writes LOIs, but this one is a MAJOR MISTAKE. I have debated this topic for 30 years and now my argument just got squashed by the agency. In their 2025 LOI, OSHA stated: If the employer’s evaluation of the space determines that…...

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Is this where we have arrived with Tech in the Safety Arena?!?! (Virtual PIT Evaluations?)

Background: 29 CFR 1910.178(l)(2)(iii) states: All operator training and evaluation shall be conducted by persons who have the knowledge, training, and experience to train powered industrial truck operators and evaluate their competence. Question #1: Can a person who has the knowledge, training, and experience to train powered industrial truck operators and evaluate their competence, clarified…...

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Whether the respiratory protection medical evaluation may consider factors beyond respirator use (OSHA LOI)

OSHA answers two (2) Respiratory Protection Program questions: To what extent does OSHA’s Respiratory Protection standard, at 29 CFR ยง 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?Is there a reasonable expectation…...

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