OSHA Compliance

Is N-Methyl-2-pyrrolidone (NMP) solvent considered a “Toxic” under the International Fire Code

Under the International Fire Code (IFC), N-Methyl-2-pyrrolidone (NMP) is not classified as a “Toxic” or “Highly Toxic” material. While NMP is legally classified as a toxic substance under environmental and labor laws (such as the EPA’s TSCA and OSHA’s Hazard Communication Standard) due to its health effects, the IFC uses a very specific, narrow definition…...

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Grand Rapids, MI Flammable Liquid Code (.ppt)

I’m in Grand Rapids this week working with a client on a flammable liquids process that is under the PSM TQ, but over the Maximum Allowable Quantity for “outside”. The city began adopting the IFC in 2006 and is now using the 2021 edition. I am sharing the PPT file for the management presentation/training, if…...

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Can I do QLFT on a full-face APR?

The short answer is NO, but if we do, there’s a significant catch regarding its protection rating. Under OSHA standards (29 CFR 1910.134), you are technically allowed to perform a Qualitative Fit Test (QLFT) on a full-face respirator, but doing so limits its Assigned Protection Factor (APF) to 10. Here is the breakdown of why…...

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If I do RT examinations of 100% of my pipe welds, do I get any exemptions for pressure/leak testing?

The short answer is no. Radiographic Testing (RT) and pressure testing (Hydrostatic or Pneumatic) serve two (2) fundamentally different purposes in piping integrity. While it might seem like “over-testing,” they are not interchangeable in ASME B31.3 (Process Piping) or ASME B31.1 (Power Piping). Here is the breakdown of why 100% RT does not exempt you…...

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Two sanitation workers die cleaning a sewer in Nuh, one critical (1 entrant, 1 Would-be Rescuers)

Two (2) sanitation workers were killed, and a third was hospitalized in critical condition after they inhaled toxic fumes while cleaning a sewer line. The incident took place around 10.30 pm. The workers were employees of the local Municipality. “Preliminary investigation revealed that the first worker entered the sewer and failed to come out for a…...

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Training that matters (Dwight Schrute Fire Drill)

This is hands down the best comedic scene for safety pros! Dwight revolts against the office personnel for not paying attention to his PowerPoint training on Fire Drill. So he took matters into his own hands…… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Auditing in terms of a SMS function and Continuous Improvement

We have a long-time client for whom we have now completed OSH and/or PSM/RMP audits at all of their North American facilities over the past 8 years. And this last audit was a “deal breaker” for many clients, as they were fit to be tied after the audit. Seems the facility had run its Safety/PS…...

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Vacuum is an ENERGY SOURCE (video)

I share this, as many may not recognize the power of a vacuum as a form of hazardous energy. ZERO = 0 and a vacuum is NOT zero, its actually LESS THAN ZERO! I added this video to the library this weekend. It demonstrates the power of a vacuum and why ALL energy sources MUST…...

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Another simple asphyxiant event where WARNING Signs and Oxygen Sensors could have saved a life

This event involved argon, a simple asphyxiant gas. The facility stored its Argon cylinders inside the 47,000 sq ft building, approximately 55 ft from where the workers were overcome. The Technical Sales representative from National Welders responded to the scene and tested for oxygen deficiency. He tested the system line at 100 psi, which revealed…...

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Process Safety introduced the MOC to many, but it did NOT create the MOC

One of my most debated topics at SAFTENG is my writings/ramblings about the critical role that a Management of Change (MOC) plays in ALL of safety, not just PSM. I’ve been involved in numerous non-PSM/RMP accidents that can be traced to poor or non-existent change management. One fatal event last year involved simply moving a…...

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JLG strikes NH3 pipe leading to a fatality

Workers were weatherproofing the outer layer of a large ammonia storage tank when contractor-operated equipment struck a bleed pipe, causing an unplanned release of ammonia. Two (2) workers were exposed to ammonia, one worker suffering fatal injury and the other worker suffering minor injuries. NOTE: Another case of an EEBA not working because it was…...

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Stove switch hit while moving mattress leads to LPG explosion

While moving a mattress, employees accidentally bumped a stove knob, turning on the gas, which was left on overnight. This allowed gas to accumulate inside the camper. When the supervisor entered the unit, fresh air mixed with the propane, creating a flammable concentration. Once the power for lighting was restored, the ignition occurred, resulting in…...

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