OSHA Compliance

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 […]

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

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

Locking slide on 1/4-turn ball valves

I know many safety professionals will know this, but when we ask operators or “Authorized Employees”, the vast majority have never been trained on the lockout mechanism on these 1/4 turn ball valves!!! Once we know and we use them, should they be fixed/replaced when we find them broken or missing? Of course, we can

Requirements for our BULK Tranfer Hoses in a PSM/RMP Process

Recently, I had the opportunity to help a client gain the full picture of what has to be done regarding the BULK TRANSFER hoses to unload their HHC/EHS from Tanker Trucks/ISO Containers and Railcars. Now, before we get into the specifics, I know a number of folks will fall back on the compliance position that

Evacuating the Hazardous Materials to achieve a ZES can be more dangerous than the actual maintenance

Last week, David Ayers, Ph.D., CSP, CHMM, and I had a nice chat regarding LOTO and Complex Processes, and one of the areas associated with these LOTOs is the “evacuation” of the HAZMAT within the process/system. We did not have enough time for me to get deep into the weeds on this aspect of isolating

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