OSHA Compliance

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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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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