OSHA Compliance Posts

Have you seen these? Where do they belong?

Here we have three (3) chemical labels, each one very different from the other and all three have a different agency/organization that oversees their use.  All three (3) are for the Category 3 Flammable Liquid Xylene, CAS# 1330-20-7.  The question is… Does it matter where/how these three (3) labels are used on containers of Xylene? I…...

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6-hr Intermediate HAZCOM/HAZMAT (.ppt)

For the SAFTENG members This is my 2019 version of the GHS HAZCOM and Behavior of Hazardous Materials training ppt. The course does what I like to call “Compliance to Science”; it covers OSHA’s GHS requirements and then gets into the behaviors of hazardous materials.  The course is intended to ensure that users of SDS’s…...

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Protecting sprinklers during Hot Work

Sprinklers save lives and they save billions of dollars each year from fire losses; however, if a head is activated accidentally, we can suffer serious damage from all the water and the downtime.  So protecting our heads from accidental discharge is as important as protecting them from contamination and delayed activation.  In this article, I…...

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2018 OSHA Emergency Action Plan (1910.38) activity by Industry Sectors

Here is a look at OSHA’s Emergency Action Plan (1910.38) compliance activity in 2018 (October 2017 – September 2018). As you can see, OSHA issued 80 citations from 66 inspections for a total of $155,698 in fines.  Here is a quick breakdown of activity: 49311 / General Warehousing and Storage with 4 citations totaling $21,878 32221 / Paperboard Container…...

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2018 OSHA Employee Emergency Alarm (1910.165) activity by Industry Sectors

Here is a look at OSHA’s Employee Emergency Alarm (1910.165) compliance activity in 2018 (October 2017 – September 2018). As you can see, OSHA found issues with complying with this standard on 10 inspections and issued 10 citations for a total of $17,147 in fines.  Here is a quick breakdown of activity: 49111 / Postal Service with 2 citations…...

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In the working world of codes, standards, regulations, and rules two little bitty words carry a lot of weight

In our daily work as safety professionals, we are guided by a lot of codes, standards, regulations, and rules that are intended to establish a baseline, albeit a minimum level of risk control.  These codes, standards, regulations, and rules can be confusing to many who tried to read or interpret what the agency/group intends with their requirements. …...

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In the working world of codes, standards, regulations, and rules two little bitty words carry a lot of weight Read More »

Forklift vs. Ammonia Piping

At 11:30 a.m. on January 23, 2018, an employee was moving product in a freezer with a forklift. The forklift struck UNPROTECTED refrigeration piping, breaking a valve and releasing anhydrous ammonia. The employee’s face, eyes, and chest were exposed to the anhydrous ammonia and the employee was hospitalized…. Membership Required You must be a member...

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GHS does not require SDS to provide NFPA or HMIS labeling information, but when they do – IT MUST BE CORRECT

Over the past four (4) years, I have been involved in an industry that I would have never thought would be some of my Process Safety clients and over these same four years, I have come to feel sorry for an entire industry.  This industry was forced to change to an alternative chemical in order…...

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GHS does not require SDS to provide NFPA or HMIS labeling information, but when they do – IT MUST BE CORRECT Read More »

OSHA, the IFC, and your Emergency [egress] Lighting

This morning we had some serious weather pass through the Cincinnati area and many areas lost power.  Ironically I was conversing with a client in MI about the topic of emergency lighting inspections when the power at the facility I am at this week went out.  Of course, this facility’s emergency lighting activated and worked…...

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OSHA further clarifies in-plant labeling vs. “shipped containers” labeling under the GHS (1910.1200(f)(1) 1910.1200(f)(6) 1910.1200(f)(7)

Background: Your company has an internal communication method to communicate the identity of hazardous chemicals transported on company vehicles from one location to another location within the same building (intra-plant). This method uses words, pictures, and/or product identification number, NFPA, HMIS, or DOT identifiers. The company also uses this communication method when transporting hazardous chemicals…...

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OSHA further clarifies in-plant labeling vs. “shipped containers” labeling under the GHS (1910.1200(f)(1) 1910.1200(f)(6) 1910.1200(f)(7) Read More »

OSHA LOTO, PRCS, PPE, Emergency Response, HAZCOM, ESRWP citations @ heat treat business ($1.3M)

OSHA has proposed penalties of $1,326,367 to a metal heat treatment company after the company exposed employees to atmospheric, thermal, electrical, and mechanical hazards as they performed maintenance inside heat-treating furnaces. In addition to the penalties, OSHA placed the company in the Severe Violator Enforcement Program.  OSHA cited the company for 25 willful, serious, and…...

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OSHA LOTO, PRCS, PPE, Emergency Response, HAZCOM, ESRWP citations @ heat treat business ($1.3M) Read More »

OSHA LOTO and PRCS citations @ railroad ties manufacturer ($120K)

OSHA has cited a manufacturer of railroad ties, with 16 safety violations, including one willful, following the crushing death of a worker who was caught in a machine.  The willful violation is failing to install guards to prevent access to the rotating and moving parts of a pre-plate boring machine used to drill holes into…...

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OSHA LOTO and PRCS citations @ railroad ties manufacturer ($120K) Read More »

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