OSHA Compliance Posts

Incorporated by Reference (IBR) database

Incorporated by Reference (IBR) is the act of including a second document within another document by only mentioning the second document.  This act, if properly done, makes the entire second document a part of the main document. Incorporation by reference is found over 1,445 times in OSHA standards, with 949 being related to the General…...

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Actions Needed to Improve Reporting of Summary Injury and Illness Data (2021)

GAO’s analysis of Occupational Safety and Health Administration (OSHA) data showed that the number of recordkeeping violations OSHA cited fluctuated over 15 years. An April 2012 federal court decision (that effectively limited the time period for citing these violations) and a January 2015 expansion of OSHA’s rule for reporting severe injuries and illnesses coincided with…...

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OSHA’s position on making flammable gas subcategories 1A and 1B

As I have said, this is all about the “environmental movement” to reduce the regulatory burdens on flammable refrigerants and not about worker safety!  You can read OSHA’s own words about by they are proposing this change… OSHA is proposing several changes to the Flammable Gases hazard class (Appendix B.2). Most significantly, OSHA is proposing…...

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Do you have a “RED TAG” program in place for your fixed fire protection systems?

Most insurers these days require this type of management program, although they may be called something else. The idea is that BEFORE a fixed system is removed from service, someone will notify the insurer about the removal from service. The insurer will then require a host of actions to be taken during the time the…...

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OSHA proposing to update the HAZCOM standard to align with UN’s GHS 7th revision

We knew this was coming; I have been writing about it for several years and what we should expect with this revision.  SAFTENG members can read what this HAZCOM revision could do to the PSM standard and Flammable Liquids standard. If OSHA adopts Part 2 of the UN’s GHS, what will Flammable Gases look like? ……...

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Damaged electrical wire inside cabinet causes electrocution OUTSIDE of cabinet

We should NEVER accept damaged electrical wires – EVEN when they are inside an electrical cabinet!  Case in point… A 30-year-old male employee was troubleshooting an issue with an injection molding machine and apparently was electrocuted when he contacted the frame of the loading conveyor. The company is a manufacturer of injection-molded, polyvinyl chloride (PVC)…...

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Damaged electrical wire inside cabinet causes electrocution OUTSIDE of cabinet Read More »

Does the IFC 2021 require fire extinguishers on forklifts?

To be blunt, the 2021 IFC does NOT require fire extinguishers on PITs (e.g., forklifts). The revision to the 2021 IFC merely gives storage (S) occupancies a NEW option for providing fire extinguishers. The new option is that when the S occupancy can meet certain requirements (as shown and explained below) they can put fire…...

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The LIMITED MEANS to perform electrically “energized work”

I do not write a lot about Electrical Safety-Related Work Practices (ESRWP) as I tend to leave this area of safety to those who specialize in it.  But as safety professionals, we MUST be trained in these safety practices so as to ensure our workers are being protected by following these ESRWPs.  The #1 failure…...

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Some Major Changes for NFPA 70E 2021 Edition

From NFPA’s 2021 70E Factsheet… Article 110: Some requirements in Article 110 have been reorganized for a more logical progression, including moving general principles of lockout/tagout from Section 120.2 and general principles of an electrically safe work condition and energized work requirements from Section 130.2. New subsection 110.5(K) REQUIRES that an employer’s electrical safety program…...

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Argon cylinders leak causing 4 employees to be hospitalized

At approximately 5:40 pm. on October 17, 2007, a wiring employee came to a press brake to get more pieces from Employee #1, a press operator. Employee #1 turned and put down a piece, collapsed to the floor, and experienced convulsions. The wiring employee panicked and asked the laser operator for help. The laser operator…...

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Inert Gas hazards associated with MIG (metal inert gas) and TIG (tungsten inert gas) welding

On December 31, 2008, a welder was preparing to conduct TIG welding on a 2″ X 65″ run of pipe located in the vent trunk compartment of an aluminum vessel under construction. The estimated height where the pipe entered the compartment was about 1.5′ from the bottom of the deck…. Membership Required You must be...

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