OSHA Compliance

The difference between and “inspector” and “examiner” (ASME B31.3)

Under ASME B31.3 (Process Piping), the roels and requirements for an Examiner are distinctly different from those for an [Owner’s] Inspector. While the Inspector represents the owner and audits the work, the Examiner represents the manufacturer, fabricator, or erector and is the person actually performing the quality control examinations—including visual inspection. Because ASME B31.3 classifies […]

OSHA and weather reporters

In the recent Supreme Court hearings, the nominee was asked about his position on the Sea World Fatality with the killer whale.  He disagreed with OSHA’s authority to cite Sea World and a member of Congress asked him about his decision.  He stated “precedent” as to why he ruled that way and since then there

Does color coding on your NFPA 704 Diamond matter?

In the past several years the use of NFPA’s 704 “Diamond” as a means for secondary labeling has seen much scrutiny; however, even OSHA has stated that this label can be used as an in-house secondary label under the GHS labeling requirements. (SAFTENG members can see my earlier articles on this topic in the OSHA

Going above OSHA minimums on Fit Factor(s)

As many of you know, I love to use other codes and standards that take my programs above and beyond OSHA minimums.  That even includes using standards and codes from other countries.  One area of safety that we can easily achieve a level above OSHA minimums is our “fit factors.”  We know that OSHA has

OSHA machine guarding citations to steel fabrication facility and its staffing company (multi-employer citation OSHRC)

The staffing company contests a two-item Citation and Notification of Penalty (Citation) issued March 20, 2017, by the Secretary. The Secretary issued the Citation following an inspection by OSHA on November 21, 2016, of a steel fabrication facility, in response to a report of a serious employee injury.  The injured employee was one of several

Are your LOTO “machine specific” procedure actually “specific” and the OSHRC settles the debate about isolating a PRCS

This 2018 decision is a MUST read for all safety professionals who wish to question the requirement for “machine specific” isolation procedures for “complex processes” AND for those who want to understand the isolation expectation for entry into a PRCS.  This business made two mistakes that run rampant in businesses when it comes to the

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