Having had the privilege of working with a railroad this year, I have learned a lot about how “safety” functions in an industry sector I knew absolutely nothing about. But in this time, I have come to really like the Federal Railroad Administration’s (FRA) approach to managing safety across this industry. The FRA had to…...
The Federal Railroad Administration and it’s Performance Oriented RRP Read More »
Both 1910.178 and 1910.147 have requirements that we periodically evaluate employees’ performance in their ability to perform LOTO and drive PITs in the manner in which they were trained. As I have discussed many times, just doing annual LOTO training without some type of “field verification” that the authorized employees are functioning within the program’s…...
1910.178 3-year evaluations and 1910.147 periodic inspections Read More »
So in my previous post, we covered the SIZE of the EXIT signs and in this post, I want to cover the “illumination” requirements of these EXIT signs. Simply stated, OSHA and the IBC require the face of the sign to be illuminated to at least 5-foot candles or 54 Lux at ALL TIMES. Which…...
What the heck is 5-footcandles, why does it matter, and what does it look like? Read More »
Earlier this year we were asked to assist in a site assessment after a tragic accident. During this assessment, it was hard not to notice all of the brand new exit signs the facility had put up (i.e. stuck up as they were stickers). These signs were super clean as compared to the rest of…...
Size Matters… ever heard that one before? Read More »
In the latest craze with “lean manufacturing”, a lot of businesses are rearranging their production lines and in a lot of cases, safety was not a serious consideration. We see a lot of emergency egress issues, serious electrical power constraints leading to improper power cord usage, fire extinguisher types and placement issues, etc. But the…...
Scenario: You have a hazardous material that has a really low PEL and STEL and the process where it is going to be used is an “open process”. Management ask you to perform a hazard assessment and it is determined that the room where this material will be used will need ventilation to ensure exposures…...
You walk by a power transmission shaft and notice that it is protruding out and seems to be missing its guard/cap. You look all around for it, as we usually can find them sitting on the floor nearby!!!, but no luck. So you report the “hazard” and issue a work-order to install a guard/cap over…...
Measurement of unguarded, rotating, shaft ends (1910.219(c)(4)(i) Read More »
I have to first point out that OR-OSHA is a “state plan” ( and my personal favorite!) and is specific to employers in the state of Oregon (OR), but their 2020 LOI on maintaining SDSs electronically points out something that many (including me) have not considered. I have been telling all my clients for decades…...
OR-OSHA points out how we can go 100% electronic with our SDSs Read More »
OSHA has updated their COVID Frequently Asked Questions (FAQ) with the addition of three (3) new Q and A’s regarding COVID vaccinations and recordability related to adverse reactions to the vaccine:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
OSHA updates their COVID FAQs as it relates to “employer required vacinations” Read More »
OSH ACT of 1970 Section (5)(a)(1): The employer did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause death or serious physical harm in that employees who performed hydrostatic testing were exposed to struck-by hazards due to the lack of specific testing procedures…...
Hazards of hydrostatic testing Read More »
The federal OSHA standard(s) are not very helpful when it comes to guidance on guarding hot surfaces and this causes many debates during audits, HAZ assessments, and Pre-Start Up Safety Reviews (PSSR). We probably are all aware of the seven (7) feet rule for guarding “fan blades”… 1910.212(a)(5) Exposure of blades. When the periphery of…...
How close can we get to hot piping/equipment before it requires guarding? (ASTM C1055) Read More »
Most safety professionals attribute “safe work permitting” to process safety, Line Breaks/Process Openings, LOTO, Hotwork, and PRCS. But my first exposure to work permits was because of OSHA’s Hazardous Communications standard… 1910.1200(e)(1)(ii) The methods the employer will use to inform employees of the hazards of non-routine tasks (for example, the cleaning of reactor vessels), and…...
My first exposure to Safe Work Permits was because of OSHA’s HAZ COMM standard – not PSM Read More »
