OSHA Compliance

Technical Analysis: The Risks of Pneumatic vs. Hydrostatic Testing

A catastrophic incident at an engineering facility serves as a definitive case study in the dangers of improper pressure testing. A technician suffered life-altering injuries when a 335-liter (88-gallon) vessel exploded during a pressure test. The root cause was a fundamental failure in hazard control: the company opted to use compressed air (pneumatic testing) instead…...

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Improper cleaning and lubricating breakers leads to explosion

Investigation into an explosion of a High-Voltage (HV) circuit breaker indicated that recently carried out maintenance may have been a causal factor. The incident resulted in catastrophic failure of the HV circuit breaker leading to fire/explosion and could have resulted in fatal injuries. Maintenance of HV and LV circuit breakers typically involves both the cleaning…...

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How many Flammable Cabinets can I have inside a single control area?

This question causes quite the debate during our audits/assessments! My record is 27 full-size cabinets in a single control area. It was actually inside a single, but large room that had NO fire ratings. And when I began to question the number and load of flammables in the room, you would have thought I shot…...

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The Federal Railroad Administration and it’s Performance Oriented RRP

Having had the privilege of working with a railroad this year, I have learned a lot about how “safety” functions in an industry sector I knew absolutely nothing about.  But in this time, I have come to really like the Federal Railroad Administration’s (FRA) approach to managing safety across this industry.  The FRA had to…...

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1910.178 3-year evaluations and 1910.147 periodic inspections

Both 1910.178 and 1910.147 have requirements that we periodically evaluate employees’ performance in their ability to perform LOTO and drive PITs in the manner in which they were trained.  As I have discussed many times, just doing annual LOTO training without some type of “field verification” that the authorized employees are functioning within the program’s…...

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What the heck is 5-footcandles, why does it matter, and what does it look like?

So in my previous post, we covered the SIZE of the EXIT signs and in this post, I want to cover the “illumination” requirements of these EXIT signs. Simply stated, OSHA and the IBC require the face of the sign to be illuminated to at least 5-foot candles or 54 Lux at ALL TIMES.  Which…...

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Size Matters… ever heard that one before?

Earlier this year we were asked to assist in a site assessment after a tragic accident.  During this assessment, it was hard not to notice all of the brand new exit signs the facility had put up (i.e. stuck up as they were stickers).  These signs were super clean as compared to the rest of…...

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Consider NFPA 70E Shock Protection Boundaries when laying out production machines/equipment

In the latest craze with “lean manufacturing”, a lot of businesses are rearranging their production lines and in a lot of cases, safety was not a serious consideration.  We see a lot of emergency egress issues, serious electrical power constraints leading to improper power cord usage, fire extinguisher types and placement issues, etc.  But the…...

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OSHA’s 1910.94 is very limited in application, so what is one to do when needing to design a ventilation/exhaust safety system?

Scenario:  You have a hazardous material that has a really low PEL and STEL and the process where it is going to be used is an “open process”.  Management ask you to perform a hazard assessment and it is determined that the room where this material will be used will need ventilation to ensure exposures…...

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Measurement of unguarded, rotating, shaft ends (1910.219(c)(4)(i)

You walk by a power transmission shaft and notice that it is protruding out and seems to be missing its guard/cap.  You look all around for it, as we usually can find them sitting on the floor nearby!!!, but no luck.  So you report the “hazard” and issue a work-order to install a guard/cap over…...

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OR-OSHA points out how we can go 100% electronic with our SDSs

I have to first point out that OR-OSHA is a “state plan” ( and my personal favorite!) and is specific to employers in the state of Oregon (OR), but their 2020 LOI on maintaining SDSs electronically points out something that many (including me) have not considered.  I have been telling all my clients for decades…...

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OSHA updates their COVID FAQs as it relates to “employer required vacinations”

OSHA has updated their COVID Frequently Asked Questions (FAQ) with the addition of three (3) new Q and A’s regarding COVID vaccinations and recordability related to adverse reactions to the vaccine:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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