OSHA Compliance

The sad state of Hazard Communications in safety

It’s been 8 years since we have been using the Globally Harmonized System for our Hazardous Communications.  This much-needed update to OSHA’s HAZCOM standard was intended to correct many bad practices and to “harmonize” the USA with the rest of the world.  One of the big drivers for this change was the need to formalize…...

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Cigarette lighters in pockets during hotwork – Allow or Prohibit?

Does your business allow workers to carry their personal lighters in their pockets?  In my word of Flammable Liquids and Gases (FLAGs) and HAZ MATs we never allowed people to have lighters on them while on our property – some companies do not even allow them in parking lots. In most of my plants, our…...

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Another welding on used container fatality

At 12:00 p.m. on November 5, 2019, Employee #1 was making a small spot weld on a piece of metal. He was performing the weld on a drum that contained windshield washer fluid, a CATEGORY 3 Flammable Liquid. There was an explosion, and the drum hit the employee’s face. Liquid splashed on the employee and…...

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OSHA issues a new CPL for Silca Exposures

This new Instruction establishes OSHA’s field inspection and enforcement procedures designed to ensure uniformity when addressing respirable crystalline silica exposures in the workplace. These two new expanded health standards, general industry/maritime (29 CFR § 1910.1053) and construction (29 CFR § 1926.1153), were published in the Federal Register on March 25, 2016, and became effective June…...

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The internet sensation… face coverings can cause headaches due to lack of Oxygen (Truth or Fiction?)

If you have not seen it yet, just wait and one of your anti-mask friends will be sure to share it with you.  My phone blew up this weekend from e-mails, texts, and FB messengers from friends concerned with what they saw before their very eyes.  I tried to explain what they were seeing, but…...

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Why can’t we use the PRESSURE CHANGE TEST in ASME Section V for leak testing B31.3 piping?

ASME B31.3 does not permit the use of an “ASME Section V Pressure Change Test” as a substitute for the mandatory leak testing requirements (hydrostatic, pneumatic, or initial service leak test) defined in Chapter VI of the B31.3 Code. Why It Cannot Be Used as a Substitute:… Membership Required You must be a member to...

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OSHA HAZ COM citiations after Nitrogen asphyxiation fatality

I am sharing this citation as Nitrogen (N2) use is becoming more and more popular in businesses that often times may not have the level of safety necessary to store and handle this level of hazardous materials.  I have personally seen N2 being used in personal grooming services and microbrewing and now this was a…...

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Requirements for when rooms or buildings exceed the maximum allowable quantity per control area for flammable liquids

5705.3.7 Rooms or buildings for quantities exceeding the maximum allowable quantity per control area.Where required by Section 5705.3.5.3 or 5705.3.6.1, rooms or buildings used for the use, dispensing, or mixing of flammable and combustible liquids in quantities exceeding the maximum allowable quantity per control area shall be in accordance with Sections 5705.3.7.1 through 5705.3.7.6.3…. Membership...

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OSHA, Hot Work, and our Grandfathers

A few weeks back one of my good friends and a hell of a process safety professional contacted me about OSHA’s Hot Work (HW) referenced RAGAGEP, NFPA 51B.  He wanted to be sure he was not missing something, as OSHA still references the Year 1962 Edition of NFPA 51B.  Just to show how broken OSHA…...

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When is a pressure vessel not really a pressure vessel?

When is a pressure vessel not really a pressure vessel? A question that comes up often. And the answer may surprise you. The NBIC and ASME agree on this topic…… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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OSHA Discretion in Enforcement when Considering an Employer’s Good Faith Efforts During the COVID-19 Pandemic

In light of the coronavirus disease 2019 (COVID-19) pandemic, OSHA understands that some employers may face difficulties complying with OSHA standards due to the ongoing health emergency.  Widespread business closures, restrictions on travel, limitations on group sizes, facility visitor prohibitions, and stay-at-home or shelter-in-place requirements may limit the availability of employees, consultants, or contractors who…...

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How fast is a 10 cm/sec flame front?

As we have discussed, the latest revisions of the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) has a new criterion for categorization of flammable gases.  The GHS now has sub-categories of CAT 1 Flammable Gases:  1A and 1B.  CAT 1B flammable gases have a fundamental burning velocity of less than 10 cm/s. …...

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