OSHA Compliance

Two (2) terms (Blind and Blank) that get misused in energy isolation discussions

First, I am as guilty as anyone for using these terms interchangeably, but this week I was in a deep discussion on PRCS Isolation and those on the other end of the phone were getting confused as I was using these terms interchangeably. So I am setting the record straight on this topic, as it

OSHA Plans to submit another NPRM for LOTO in November

Recent technological advancements that employ computer-based controls of hazardous energy (e.g., mechanical, electrical, pneumatic, chemical, and radiation) conflict with the Occupational Safety and Health Administration’s (OSHA) existing lock-out/tag-out (LOTO) standard. The use of these computer-based controls has become more prevalent as equipment manufacturers modernize their designs to increase productivity. Additionally, National Consensus Standards have evolved, and

I had to ask… Can a PRCS be reclassified using (c)(7) if the piping passing through remains “charged” with a hazardous material?

My official question to OSHA was… Recently, OSHA issued an LOI aligning with NFPA 350 regarding PRCS isolation. In particular, OSHA stated that a pipe passing through a PRCS but not terminating within the space would NOT have to be isolated and evacuated. I want to know if this practice would be acceptable if the

OSHA has proposed $3.5M in fines for violations by 3 employers during a Houston facility chemical spill response

OSHA has proposed more than $3.5 million in fines against three (3) companies after federal inspectors determined they failed to protect workers during post-emergency response cleanup after a chemical spill at an industrial facility in Channelview. OSHA initiated three (3) inspections following a Dec. 27, 2025, sulfuric acid spill that resulted in multiple employee injuries.

OSHA and NFPA have aligned on “the potential” for a HAZ ATM within a PRCS, but would you “reclassify” the space under their guidance?

Both OSHA and NFPA state that if the pipe does NOT terminate within the space, the pipe does NOT have to be evacuated to consider the contents of the pipe a “potential” to generate a HAZ ATM. In a recent OSHA LOI, OSHA used several thresholds that the employer should/must use in its evaluation of

Almost 50% of serious HAZMAT transportation incidents occur during loading and unloading operations

The transfer of hazardous materials from a cargo-tank motor vehicle to fixed-site storage poses a critical vulnerability in chemical handling. While high-speed highway collisions capture more attention, the Pipeline and Hazardous Materials Safety Administration (PHMSA) estimates that roughly 25% to 50% of serious HAZMAT transportation incidents actually occur during loading and unloading operations. These accidents

What is the Welding Certification actually evaluating when the welding will be done by a pipe welding machine?

When we introduce a pipe welding machine (such as an orbital welder) into the fabrication process, the focus of the certification fundamentally shifts. Under industry codes such as ASME Section IX, the individual operating the equipment is no longer classified as a “Welder”; they are designated as a “Welding Operator.” Because the machine handles the

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