OSHA Compliance

OSHA uses the word “specific” 10 times in its LOTO standard and yet…

OSHA uses the word “specific” 10 times in its LOTO standard, and yet, the vast majority of the LOTO programs we come across are not even specific to the facility, much less specific in how they define and quantify critical elements. To save you time from looking them all up to prove I’m wrong, here…...

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Understanding 1910.147(d)(5)(ii) (Reaccumulation of Energy)

OSHA 1910.147(d)(5)(ii) is one of the most critical, yet frequently overlooked, requirements of the Lockout/Tagout (LOTO) standard. It moves LOTO from a static, one-time task (“lock it and check it”) to a dynamic process that accounts for the physical reality of residual and regenerative energy. Think about isolating “compressed air” to a machine/equipment and the…...

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Waste management company fined $130,000 after workers were injured in a flash fire caused by a Vac Truck

Four (4) workers were injured at a worksite on April 30, 2024, while offloading flammable solvents from a vacuum truck into a storage tanker. At the same time, other workers positioned a hydrovac truck in an adjacent bay to offload a wastewater-and-slurry mixture. During this process, flammable vapors were released and drawn into the idling…...

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Interesting Lawsuit against Company (Fire Watch issues)

An independent contractor in Denton, Texas, was severely burned and fell from an extension ladder after his clothing ignited during a flash fire. The worker was torch-cutting steel walls on a transformer unit to dismantle it for a scrapyard. A lawsuit filed in late June alleges the provided fire watch was improperly positioned and inattentive…....

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Line Break gone bad (Flammable Gas)

Sinopec Yangzi Petrochemical (May 29, 2026): Four workers died during shutdown maintenance at an ethylene plant in China. The flash fire occurred while operations personnel were disassembling a cracking valve. Early investigations point to incomplete emptying and purging of the pipe, which left residual cracking gases (ethylene, propylene, and butadiene) inside. The suspected ignition source…...

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OSHA emergency response standard update

The proposed OSHA Emergency Response standard is currently in the final review stages. According to OSHA’s most recent Unified Agenda (published in July 2026), the final rule is projected to be published in April 2027. Once finalized, this rule will completely replace the outdated 1980 “Fire Brigades” standard (29 CFR 1910.156) and dramatically expand basic…...

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Piping MAWP vs Burst Pressure are VASTLY different

Many in safety may not recognize that the “burst pressure” of piping is NOT the same as the Maximum Allowable Working Pressure (MAWP). ASME B31.3 requires the facility to identify and work within the MAWP. For those who may not know the difference and why it matters…… Membership Required You must be a member to...

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2026 UPDATES to NFPA 2, Hydrogen Technologies Code

The 2026 edition of the code no longer relies on cross-referencing NFPA 55. This code now has full scope over all requirements related to hydrogen storage, use, and handling. This is a result of the NFPA Standards Council clarifying that the scope of the technical committee responsible for revising this code must be referred to…...

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Two (2) terms (Blind and Blank) that get misused in energy isolation discussions

First, I am as guilty as anyone for using these terms interchangeably, but this week I was in a deep discussion on PRCS Isolation and those on the other end of the phone were getting confused as I was using these terms interchangeably. So I am setting the record straight on this topic, as it…...

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OSHA Plans to submit another NPRM for LOTO in November

Recent technological advancements that employ computer-based controls of hazardous energy (e.g., mechanical, electrical, pneumatic, chemical, and radiation) conflict with the Occupational Safety and Health Administration’s (OSHA) existing lock-out/tag-out (LOTO) standard. The use of these computer-based controls has become more prevalent as equipment manufacturers modernize their designs to increase productivity. Additionally, National Consensus Standards have evolved, and…...

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I had to ask… Can a PRCS be reclassified using (c)(7) if the piping passing through remains “charged” with a hazardous material?

My official question to OSHA was… Recently, OSHA issued an LOI aligning with NFPA 350 regarding PRCS isolation. In particular, OSHA stated that a pipe passing through a PRCS but not terminating within the space would NOT have to be isolated and evacuated. I want to know if this practice would be acceptable if the…...

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B.C. firm fined $110K after wood fiber engulfs worker in horrific PRCS fatal incident

A fire ignited inside a silo (a confined space) at this firm’s sawmill, and the water used to extinguish it had frozen the wood fiber inside the silo. While a subcontractor’s worker was pressure washing the fiber inside the silo, a large volume of fiber dislodged from an overhang above the work area. The fiber…...

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