OSHA Compliance

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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Combustible Dust and the 8th Revision of the Globally Harmonized System of Classification and Labelling of Chemicals (GHS)

The United Nations issued its 8th Revision to the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) late last year and in this 8th revision we have some very good guidance on Combustible Dust (COM DUST).  For the record, OSHA is considering adopting the 7th Revision; we currently are using the 3rd revision…...

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Interim final rule to update the regulatory requirements NIOSH to test and approve PAPRs

The Department of Health and Human Service (HHS) is publishing this interim final rule to update the regulatory requirements used by the Centers for Disease Control and Prevention’s (CDC) National Institute for Occupational Safety and Health (NIOSH)to test and approve air-purifying particulate respirators for use in the ongoing public health emergency. With this rulemaking, parallel…...

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Fire Code and CLOSED and OPEN Systems

I have written several articles lately explaining the limitations of storing flammables and toxics.  A couple of these articles referenced the International Fire Code (IFC) which is my favorite safety code for hazardous materials.  OSHA’s 1910.106 is from the 1969 NFPA 30 and has not been sustainably updated since; whereas the IFC gets updated every…...

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What is a Vertical Standard vs a Horizontal Standard?

These two terms are often discussed on OSHA outreach training courses, but I hardly ever mention them as they are more “legal” terms than safety terms.  But this month, MI-OSHA issued guidance to their CSHO’s which I thought did a really nice job explaining what these terms mean and how they are used in issuing…...

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And you wonder why OSHA writes these standards (Exit height and Working Order)

In this one, we get a 2-for-1 special!!!! First, the egress path height… 1910.36(g)(1) The ceiling of an exit route must be at least seven feet six inches (2.3 m) high. Any projection from the ceiling must not reach a point less than six feet eight inches (2.0 m) from the floor. and then the…...

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Free EHS Web Training (Listing of Resources)

From my friend Bill Geddings… In an effort to help EHS professionals who are missing conferences, local professional development meetings and other training opportunities that will allow us all to maintain certifications and our competencies please share known online learning opportunities.  These can be environmental, occupational health, safety, leadership, emergency response, etc. I will share…...

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