OSHA Compliance

Understanding the LIMITATIONS of NFPA 70, Article 500.7(k) Combustible Gas Detection System (CGDS)

In NFPA 70 (National Electrical Code / NEC), the use of a Combustible Gas Detection System (CGDS) is a highly specialized engineering provision. It essentially acts as a “get out of jail free” card—or more accurately, a reclassification tool—for specific industrial locations. When you install a qualified CGDS, the NEC allows you to lower the…...

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Two (2) common ways a vessel can exceed its MDMT

Auto-Refrigeration & Flashing and Cold Ambient Exposures We see around a half dozen pressure vessels in a “service” they were not initially designed for. There are literally hundreds of excuses as to why we find these issues, but they are simply excuses. It was not uncommon for us to find a PV in an NH3…...

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The history of “weak seam welded roof” as a means of emergency venting atmospheric storage tanks

The concept of the weak seam welded roof—officially referred to in modern engineering standards as a frangible roof joint—has been a foundational safety mechanism for atmospheric storage tanks for over 90 years. NOTE: In 2015, NFPA 30 Section 22.7 was amended to eliminate the use of a weak roof-to-shell seam as an allowed means of…...

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Massive Spike in Counterfeit Respirator Cartridges & Filters Online

In a recent case study, NIOSH researchers purchased hundreds of respirator components from major online marketplaces to test their performance, focusing on listings bearing “NIOSH” or “P100” markings from non-authorized sellers. The results show a severe influx of fraudulent PPE:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member?...

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UPDATE on the PRCS (Barge) Double Fatality event in AK

Based on recent updates from USCG and NFPA, we now know that two days after the incident, a marine chemist arrived on the scene in Alaska and tested the atmosphere of the barge involved in the accident. But the atmosphere therein had been sufficiently ventilated to allow firefighters to enter and recover the body of…...

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Failing to CLOSE a PRCS Entry Permit properly can have Process Safety implications months after the entry

As most of you know, PRCS Entry is one of the specific SWPs called out in the PSM and RMP standards. But many programs fail to meet 1910.146(f)(4), and a recent CSB accident report tied the requirement for canceling a permit to a catastrophic explosion event. 1910.119(f)(4) The employer shall develop and implement safe work…...

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OSHA Respiratory Protection Enforcement Focus: Written Program Integrity

OSHA’s regional emphasis programs continue to prioritize the programmatic elements of 1910.134. Citations in 2026 are frequently tied to “paperwork and protocol” failures rather than hardware failures:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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The 15-Year Service Life Debate for Composite Cylinders (SP 16320)

The most significant friction point involves PHMSA and SCBA Fully Wrapped Carbon-Fiber Reinforced (CFFC) aluminum-lined cylinders on Special Permit 16320 and the use of Modal Acoustic Emission (MAE) testing to extend the life of composite cylinders. Fully Wrapped Carbon-Fiber Reinforced (CFFC) aluminum-lined cylinders have a 15-year service life. PHMSA has investigated and granted limited special…...

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FRC must be the outer layer – NYLON Hi-Vis vest are a problem

In today’s workplaces, it’s hard to find a large business that does not require Hi-Vis Vest/Workwear. What is not hard to find is a business with HAZLOCs where workers are required to wear FRC but are wearing nylon Hi-Vis vests OVER their FRC. I am all for making workers more visible to powered industrial trucks…...

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SNOOP doing what it does best

I took these pics for those who may have never seen a FAILED leak test using a “bubble solution”. We have discussed the “sensitivity testing” using the bubble test method many times, as it’s the most common method. I have been using the brand SNOOP my entire career and highly recommend it. (an unpaid endorsement)…...

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Another fatal HW on used storage tank accident (video)

We have another tragic example of how dangerous hot work is on used (even new) containers when proper precautions are not taken. This event seriously injured the three (3) workers in Ankara, Turkey, in February 2024. Members can download the video from the video library…. Membership Required You must be a member to access this...

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How often do SCBA cylinders need to be “topped off” to ensure they stay above 90% full?

The amount of breathing air consumed during a monthly SCBA functional test (often referred to as the “monthly inspection” or “flow test”) varies slightly by manufacturer and the specific depth of your inspection/testing SOP. However, for a standard 30-minute/45-cubic-foot cylinder, you can estimate the usage based on the required NFPA 1852 checks…. Membership Required You...

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