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Machine guarding CNC Mills and Lathes (OSHRC Decision)

This case is significant in a number of ways:  1) manufacturer of the equipment put warning signs on their machines pointing out the hazard(s), 2) manufacturer considered the “doors” on their CNC mills and lathes to be “guards”, 3) manufacturer installed interlocks on the “doors” (i.e. guards), 4) company bought the machines “used” and many of the interlocks were not operational at…...

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Fertilizer Canada has gotten serious about Facility Siting for NH3 Ag facilities!

2016 will go down as the year OSHA and EPA tried to revamp their PSM and RMP rules for handling Highly Hazardous Chemicals (HHC) and Extremely Hazardous Substances (EHS).  We have even seen Congress get into the act of blocking OSHA from enforcing PSM on fertilizer distributors.  All the while, our friends to the north have…...

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Did the Federal Motor Carrier Safety Administration (FMCSA) just declare e-cigs an “ignition source”?

No, not directly, but they did issue this Safety Advisory: Possession or Use of Battery-Powered Portable Electronic Smoking Devices Around, On or While Operating a Commercial Motor Vehicle (CMV) relating to the possession and use of battery-powered portable electronic smoking devices (e.g., e-cigarettes, e-cigs, e-cigars, e-pipes, e-hookahs, personal vaporizers, electronic nicotine delivery systems (ENDS).  In this Safety Advisory, the…...

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Post-Accident Drug Testing and OSHA’s New Reporting Rule

This past week I worked with a client who’s safety contact is the HR manager and we had several discussions about OSHA’s revised recordkeeping requirements and all the recent reporting changes.  One thing I noticed is that ALL MANUFACTURING facilities are considered “high risk” and are on the list of NAICS’s number that must report.  So the…...

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NFPA’s 2017 Edition of NFPA 70 (NEC) will impact facilities handling Anhydrous Ammonia

For years, NFPA 70, the “National Electric Code” has exempted Engine Rooms/Mechanical Rooms for refrigeration processes using Anhydrous Ammonia from having to be Electrically Classified Hazardous Locations (HAZLOC) as long as the room had “adequate ventilation”.  The exemption in NFPA 70 has always been sort of vague and referenced the ventilation requirements in ANSI/ASHRAE 15-1994, Safety…...

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2016 Video of the Week #33 (Human Behaviors during an emergency evac… just unreal!)

As safety professionals, we are asked to perform human miracles on a weekly basis… when someone gets hurt on the job, it is our role, and far too often our role alone, to somehow make sure that not only does the injured worker not “do that unsafe act again” but to also ensure that no…...

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RMP Enforcement Data from Ohio EPA

Recently at a Compliance Assistance conference, OH-EPA presented on EPA’s Risk Management Plan and revealed some interesting data. One thing to state up front is that Ohio EPA is one of thirteen (13) states that has been delegated to enforce 40 CFR Part 68 within the state of Ohio. With that comes a snap shot…...

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OSHA PSM Citations @ chemical plant (Liquified flammable gas & $115K)

As part of the agency’s national emphasis program for chemical facilities, OSHA inspected the company on Feb. 6, 2016, and found multiple violations of federal process safety management regulations, including not developing set written procedures for maintaining process equipment, which resulted in repeat violations.  In addition, OSHA issued citations for serious violations for the following:…...

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EPA announces NEW National Enforcement Initiative: Reducing Risks of Accidental Releases at Industrial and Chemical Facilities (Fiscal Years 2017-19)

EPA has announced it will increase efforts to prevent catastrophic accidents and explosions that threaten employees and emergency responders and release chemicals that threaten human health and the environment in neighboring communities.  EPA selects National Enforcement Initiatives (NEIs) every three years to focus resources on national environmental problems where there is significant non-compliance with laws, and where…...

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