OSHA Compliance

If the source container is metal and the receiving container is nonconductive, do the bonding and grounding requirements apply? (OSHA Archived LOI and CPL)

/ Flammable Liquids, Hazardous Materials, OSHA Compliance /

Bonding and grounding two non-conductive containers would seem unnecessary, since non-conductive materials are insulators and therefore cannot conduct current through them. However, static electrical charge can be generated when two dissimilar materials pass quickly by one another (i.e., liquids flowing through pipes, even air). OSHA recognizes that there are many factors that affect the size…...

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I asked AI… what is the likelihood of workers building up a long-term tolerance to Bitrex with a once-per-year and 3-5-minute fit test?

/ OSHA Compliance, Respiratory Protection /

The likelihood of a worker building a long-term tolerance to Bitrex (denatonium benzoate) from a single 3-to-5-minute annual respirator fit test is virtually zero. Physiological habituation—where the nervous system stops responding to a stimulus—requires frequent, sustained exposure over time. A brief, once-a-year exposure is nowhere near the threshold required to alter a person’s neurological taste…...

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Does your organization recognize the difference between a Safety Policy, a Safety Program, and a Safe Work Practice?

/ OSHA Compliance, Safety Management System /

In this discussion, think about your Respiratory Protection efforts. Does the organization have a Policy on the use of RP? Does the policy statement recognize that RP is the lowest form of protection (e.g., Hierarchy of Controls) and mention that Engineering and Administrative controls will be considered BEFORE the use of RP? We then move…...

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Understanding OSHA’s Instance-by-Instance (IBI) policy

/ OSHA Compliance /

Some may agree with this policy, and others may decry government overreach. Nonetheless, the policy is real and carries some serious consequences for really bad employers. Here is a breakdown of the policy and how its being used…… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in...

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Trends in Permit-Required Confined Space Enforcement

/ OSHA Compliance, Permit Required Confined Spaces /

The enforcement climate around 29 CFR 1910.146 remains intensely focused on fundamental programmatic failures rather than isolated technical errors. When companies fail at confined space entry, it is rarely due to a nuance in the standard—it is almost always a total breakdown of core safety controls. Top 5 Citation Areas for 1910.146… Membership Required You...

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Visual Aid for Teaching PPM and % by Volume

/ Emergency Response, Hazardous Materials, OSHA Compliance /

I am always trying to give my students a visual when I begin talking about IDLH values. It’s one thing to say that Chlorine’s IDLH is 10 ppm and explain what that means within the training room. So I have been playing with some AI sources, mainly Google Gemini and ChatGPT, to create visual aids…...

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Is bonding and grounding an effective control when transferring non-conductive flammable liquids?

/ Chemical Process Safety (PSM/RMP), Flammable Liquids, Hazardous Materials, OSHA Compliance /

The short answer is no. While bonding and grounding are absolute regulatory requirements under OSHA 1910.106 and are foundational safety measures in flammable liquids safety, they are insufficient on their own when transferring non-conductive (e.g., conductivity < 50 pS/m) flammable liquids like toluene, xylene, benzene, or ultra-low sulfur diesel. This is a classic process safety…...

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Why does OSHA specifically require “forced-air” ventilation in 1910.146

/ OSHA Compliance, Permit Required Confined Spaces /

This is a follow-up to my guest appearance on Dr. David Ayer’s podcast, where we discussed “ventilating confined spaces,” and, as usual, we didn’t have enough time to go as deep as we wanted. So here is my detailed explanation as to why OSHA SPECIFICALLY calls out “Forced-Air” ventilation 7 times:… Membership Required You must...

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What is the “NO GO” for an NH3 release?

/ Emergency Response, Hazardous Materials, OSHA Compliance, Respiratory Protection /

In all my years of training, responding, and now teaching others, my NO-GO has always been 10,000 ppm. But why 10,000 ppm? Is this a Haywood thing, or is this based on science and the limitations of most direct reading instruments (DRI)? Well, here are the facts as to why 10,000 ppm should be your…...

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The need for REMOTE Emergency Shutdown

/ Chemical Process Safety (PSM/RMP), Emergency Response, Hazardous Materials, OSHA Compliance /

I thought this image was a good way to show why Codes and standards for hazardous materials such as NH3 REQUIRE REMOTE Emergency Shutdown Systems. For example, CGA 2.1 states the following:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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OSHA updates the HAZCOM CPL (Secondary Container Labeling)

/ Hazardous Materials, OSHA Compliance /

In May of this year, OSHA issued an updated version of its CPL-02-02-079, Inspection Procedures for the Hazard Communication Standard (HCS 2024). In this updated CPL, OSHA explains the requirements for “secondary containers”, which has become a hotly contested practice for unknown reasons. I have spent the past 2 years trying to correct the “internet…...

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Former Yenkin Majestic Paint Corporation, which has since been sold to new ownership, pleads guilty to negligent endangerment

/ Chemical Process Safety (PSM/RMP), Flammable Liquids, OSHA Compliance /

An Ohio corporation pleaded guilty this week in federal court in the Southern District of Ohio to a charge of negligent endangerment. The criminal charge is related to an explosion that resulted in the death of one employee and injuries to several more. Yenkin-Majestic Paint Corporation was a family-owned and operated coatings-industry supplier based in…...

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