OSHA Compliance

Worker fatality inside PRCS (Flash Fire Burns?)

An employee at a tank manufacturing facility has died following an industrial incident on Monday. Firefighters responded to a report of a burn injury. Firefighters stabilized the patient, who was taken to a hospital, where the patient died. A special operations crew and a police crew responded to investigate the scene but found nothing suspicious…....

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OSHA defines “feasibility”

In this line of work, it will not take long to hear the phrase “Is it really worth it?” We hear it when developing our Corrective Action Plans after an Audit, a PHA, or an Incident Investigation. Everyone agrees that “we need to do something”; it’s the level of that something that splits the road…...

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Does a “DANGER” sign belong on a Confined Space?

I see this set up all the time… a business declares a space a Confined Space (NOT a Permit-Required Confined Space), just a simple space that meets the definition of a CS; however, it does not have a hazard that would make the CS a PRCS. So the question is… Does a “DANGER” sign belong…...

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My explanation of Workplace Labeling vs. Shipped Containers

I have updated (4/3/26) the presentation with the NFPA direction/requirements for using the Diamond on small containers. Yes, NFPA provides specific guidance on using the Diamond on containers smaller than 1 gallon. 4/3/26 – I added the explanation as to why Bulk HAZMAT containers (Tanker Trucks & Railcars) are exempt from OSHA’s “shipped containers” requirements…...

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Can we use DOT Placards with the chemical name as “secondary container” labeling?

DISCLAIMER: I am NOT suggesting we do this; just asking the group for their thoughts on a challenge I got this week. In all the discussions about using NFPA 704 Diamonds on Secondary Containers, from laboratory squirt bottles to bulk storage tanks, today I was asked if DOT Placards could be used to label STATIONARY…...

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Would you accept this repair for one of your Polyethylene Storage tank?

I guess we are never too old to learn new tricks! This week, I came across a practice that I was 100% certain I was being “punked.” The practice is called “welding,” but it’s done on a Polyethylene Plastic tank! Technically, it meets the definition of “welding”… Welding is a fabrication process that joins materials—typically…...

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Why knowing Vapor Pressure matters

Too many safety personnel are not sufficiently familiar with the critical role Vapor Pressure (VP) plays in managing hazardous materials. From our PPE Hazard Assessments, Respiratory Protection, to how we respond to these hazardous materials when there is a LOPC event involving them. But VP also plays a major role in how we DESIGN our…...

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Storing 19% Aqua Ammonia Outside can be tricky

Over the past decade, we have received dozens of requests from both current and new clients seeking to move to 19% Aqua Ammonia, so the process is NO LONGER RMP-covered. (NOTE: OSHA only covers 44% or higher Aqua Ammonia; EPA begins its coverage at 20%). This is taking the “inherently safe” approach to process safety…....

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A simple solution for Toxic Liquids stored “outside”

Some clients have their processes/storage in the middle of a neighborhood, and I mean in the middle of a neighborhood, as we see on TV and postcards. Beautiful tree-lined streets with kids riding their bikes and moms pushing their baby strollers. Of course, the facility came first, in the 1950’s, and then the encroachment. As…...

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When we don’t DEFINE and QUANTIFY in our codes and standards

Recently, we were involved in a serious incident in which a group of contractors was overcome by a “highly toxic gas” (as defined by the state’s Fire Code) that escaped from a compressed-gas cylinder. This container, along with 42 other containers with various hazardous materials, was stored outside in an unmarked area. The contractors had…...

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What went wrong: Pipework failure leading to major chemical acid leaks (UK’s HSE)

A chemical company experienced two major uncontrolled releases of highly corrosive acids. In January 2020, approximately 300,000 litres (8,000 gallons) of hydrochloric acid leaked from the site, releasing toxic gases that forced the closure of local businesses and schools and caused residents to evacuate their homes. A second incident in August saw 87,000 litres (23,000…...

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Secondary Container Labeling, OSHA, and NFPA 704 Diamond

A lot has been said on LinkedIn about secondary container labeling, and at least seven (7) posts were absolutely wrong. Those posts have been shared more than 400 times; I wish I knew how many views. Many people agreed with the original posters that secondary containers had to be labeled the same as shipped containers…....

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