Sometimes things happen that are beyond our control as Process Safety Engineers, and in reality, this is where/how we earn our keep. As our RAGAGEP (API 510) says, “Deferrals should be the occasional exception, not a frequent occurrence.” The standard provides a rational, risk-based methodology for managing an inspection that cannot be performed by its…...
I have seen this very scenario play out at least a half dozen times in my career. GRAVITY is an energy source and can be a fatal form of energy! Here is what happened in this tragedy… At 4:15 p.m. on July 19, 2021, an employee, 38, was changing the hydraulic line on a forklift…....
OSHA standards were usually written after a day like this! (emphasis by me) 1910.36(h) An OUTDOOR exit route is permitted. 1910.36(h)(1) The outdoor exit route must have guardrails to protect unenclosed sides if a fall hazard exists; 1910.36(h)(2) The outdoor exit route must be covered if snow or ice is likely to accumulate along the…...
OSHA answers five (5) questions regarding the relatively new standard, 1910.28 Duty to have fall protection and falling object protection. And I have to admit I found a couple of their answers interesting. Question 1: 29 CFR § 1910.28(b)(9) requires fixed ladders (installed on or after November 19, 2018) that are more than 24 feet…...
Background: Company employees work with packaged consumer commodities (e.g., body wash, sunscreen, mouthwash, dish detergent, fabric softener) that are placed in finished store displays. The products are not used by employees and are shipped back to the original manufacturer for distribution, or to distribution centers for resale. SDSs are maintained for shipping and/or disposal of…...
On May 18, 2018, OSHA issued an Enforcement Memorandum for Regional Administrators, “OSHA’s use of Unmanned Aircraft Systems in Inspections,” to provide initial guidance on the use of Small Unmanned Aircraft Systems (SUAS) during compliance inspections and for other purposes. In light of recent improvements by the Federal Aviation Administration (FAA) to help SUAS pilots…...
It seems there is a faction of safety professionals who want to claim that if OSHA’s blood-borne pathogens standard is “legal”, then so would the COVID ETS. But these two standards are nothing alike. For example, OSHA defined “occupational exposure” in 1910.1030 as: Occupational Exposure means reasonably anticipated skin, eye, mucous membrane, or parenteral contact…...
Here is a look at OSHA’s HAZWOPER compliance activity in 2021 (October 2020 – September 2021). As you can see, OSHA did 24 HAZWOPER inspections and issued 48 citations for a total of $156,418 in fines. This is the SETTLED amount and NOT the initial citations. Here is a quick breakdown of activity:… Membership Required You...
Here is a look at OSHA’s Process Safety Management (PSM) activity in 2021 (October 2020 – September 2021). As you can see, OSHA did 36 PSM inspections and issued 217 citations for a total of $2,194,474 in fines. This is the SETTLED amount and NOT the initial citations. Here is a quick breakdown of activity:… Membership...
Here is a look at OSHA’s Permit-Required Confined Space enforcement activity in 2021 (October 2020 – September 2021). As you can see, OSHA did 79 PRCS inspections and issued 263 citations for a total of $1,178,577 in fines. This is the SETTLED amount and NOT the initial citations. Here is a quick breakdown of activity:… Membership...
Here is a look at OSHA’s Lockout/Tagout (LOTO) activity in 2021 (October 2020 – September 2021). As you can see, OSHA did 869 LOTO inspections and issued 1,565 citations for a total of $9,864,505 in fines. This is the SETTLED amount and NOT the initial citations. Here is a quick breakdown of activity:… Membership Required You...
In a memorandum to Regional Administrators, OSHA establishes an enforcement initiative to prevent and protect employees from serious heat-related illnesses and deaths while working in hazardous hot indoor or outdoor environments. It expands on the agency’s ongoing heat-related illness prevention campaign by setting forth the enforcement component and reiterating its compliance assistance and outreach efforts. …...
