OSHA Compliance

When an entrant is at an LEL, they are usually way beyond the PEL/TLV/STEL

When we talk about Lower Explosive Limits, most people imagine a flash-fire hazard (as they should!). But when a worker is in a flammable atmosphere, they are also being WAY OVER EXPOSED. Take the following OSHA PRCS fatality case, where the worker died from being overexposed to organic vapors. The Atlantic City Fire Department Confined…...

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Is your facility “car-sealing” OPEN it’s EW/SS isolation valves?

Here is what ANSI 358 says: (emphasis by me) 5.1.6 Eyewashes shall be capable of delivering flushing fluid to the eyes not less than 1.5 liters per minute (0.4 gpm) for 15 minutes. If shut off valves are installed in the supply line for maintenance purposes, provisions shall be made to prevent unauthorized shut off…....

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Manual addition of powders to a flammable atmosphere (NFPA 77)

As I noted in 2007, the #1 cause of process vessel deflagrations is the manual additions of powders to process vessels which have a flammable atmosphere. NFPA 77 covers this hazard with several solutions, yet many facilities are either not aware of these risks and solutions or simply have their head buried regarding these catastrohic…...

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“Switch Loading” injures worker

The definition of “switch loading: Switch loading is the hazardous practice of loading a low-vapor-pressure product (such as diesel or heating oil) into a tank compartment that previously contained a high-vapor-pressure, flammable product (such as gasoline) without first cleaning it. This creates a high risk of static electricity generation and explosion, as residual vapors can…...

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Routine Line/Equipment Opening MUST be done via SOP or SWP

This is a classic case of a “routine opening” within a PSM/RMP-covered process that turned fatal for an operator. ALL openings of a process containing a hazardous energy source, PSM/RMP or NOT, can be some of the most hazardous tasks we can ask personnel to perform. At approximately 1:00 a.m. on August 14, 2011, Employee…...

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PRCS Fatality @ Winery (HAZ ATM -N2)

An accident at a Winery in California may have caused the death of a 20-year-old winery worker on Friday, Jan. 8. He was found inside a 1,500-gallon tank and apparently died from asphyxiation. “We’re still trying to figure out exactly what happened,” said the winery president. “He was a wonderful person, a fabulous worker, and…...

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New construction is using OLD Designs (Ladders & Stairs)

In the past several years, I have had the pleasure of working on some fascinating start-ups. But the one thing they all have in common is that their ladders do not meet the new ladder standard, 1910.23. Ladders still have cages, not a fall arrest system, etc. The other thing that drives me crazy is…...

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Interim Enforcement Guidance for Handrail and Stair Rail System Requirements under 1910.28(b) and 1910.29(f)

The purpose of this memorandum is to provide interim enforcement guidance on certain handrail and stair rail system requirements under 29 CFR 1910.28(b) and 1910.29(f) to allow employers to comply with proposed changes until the effective date of any new final rule resulting from the 2021 Notice of Proposed Rulemaking (NPRM). This memorandum replaces the…...

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Why ZES matters

For those who need an image of why 1 psig can be a lethal hazardous energy source! It’s why we say ZERO ENERGY STATE (ZES) in our control of hazardous energy programs. ONLY ZERO = ZERO! SAFTENG members can download the image without a watermark at SAFTENG… Membership Required You must be a member to...

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What is considered a Lockout Device in your organization?

Most safety pros live by the LOTO standard daily, or at least weekly! If not, you may need to re-evaluate where you are spending your time! As there is no other standard that impacts manufacturing businesses and brings more value to our safety efforts than does LOTO (IMPO). So this question gets to the heart…...

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Safety Programs and Safe Work Practices are our building blocks

In 2026, cutting and pasting OSHA standards and revising a few words does NOT make for a safety program/safe work practice. Yet already this year, I have seen two LOTO programs that state Lockout and tagout devices shall be standardized within the facility in at least one of the following criteria: Color; shape; or size;…...

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Safety Programs and Safe Work Practices are our building blocks

In 2026, cutting and pasting OSHA standards and revising a few words does NOT make for a safety program/safe work practice. Yet already this year, I have seen two LOTO programs that state Lockout and tagout devices shall be standardized within the facility in at least one of the following criteria: Color; shape; or size;…...

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