OSHA Compliance

What is OSHA’s official position on the enforcement of the 140 dB peak sound pressure level?

Since the standard says, “should not exceed” rather than “shall not exceed,” is the 140 dB level a recommendation or is compliance mandatory?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Updated Enforcement Policy for Recording and Reporting of COVID-19 cases

OSHA has issued an updated enforcement policy for recording and reporting COVID-19 cases. This memorandum is to inform you that, effective immediately and until further notice, OSHA is exercising its enforcement discretion to NOT cite employers for violations of 29 CFR Part 1904 for failure to record COVID-19 cases or to report COVID-19 fatalities and…...

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3 workers die of asphyxiation while cleaning an underground tank at a dyeing mill (1 entrant and 2 would be rescuers)

Three workers died, and one is critical after suspected asphyxiation in an underground effluent treatment plant (ETP) tank at a dyeing mill. The condition of another worker remains critical, and he is undergoing treatment at a hospital… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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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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