OSHA Compliance

So here’s a trick question for you IH professionals… When I get my new SDSs, do I have to retain my old MSDS for 30 years?

One standard that OSHA failed to update when they revised 1910.1200 was 1910.1020 – Access to employee exposure and medical records.  This standard still uses the term MSDS and does not address my question about the changing of MSDS for the new SDS.  Granted, a lot of the exposure info on the new SDS(s) has…...

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Are you maintaining your heat sampling data per 1910.1020(d)(1)(ii)

As summer heat intensifies, OSHA’s focus on preventing heat related illness intensifies.  With this intensity, many employers are going hi-tech to collect “heat exposure data” to establish work practices based on exposures.  I have seen a recent increase in advertising for devices that can measure wet-bulb temperatures in workplaces and they are tying these reading…...

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Interim Enforcement Guidance for Hazard Communication 2012 (HCS 2012) June 1, 2015 Effective Date (OSHA)

 May 29, 2015 MEMORANDUM FOR: REGIONAL ADMINISTRATORS THROUGH: DOROTHY DOUGHERTYDeputy Assistant Secretary FROM: THOMAS GALASSI, DirectorDirectorate of Enforcement Programs (DEP) SUBJECT: Interim Enforcement Guidance for Hazard Communication 2012 (HCS 2012) June 1, 2015 Effective Date This memorandum is to provide additional, interim guidance on the Hazard Communication 2012 June 1, 2015 effective date.  OSHA provided…...

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Does the “voluntary use” of a “filtering facepieces” (dust masks) require the use Appendix D?

Are you providing a copy of 1910.134 Appednix D to each employee who wears a filtering facepieces (dust masks) on a “voluntary basis”? Are you controlling these filtering facepieces (dust masks) so that ONLY employees who have been provided with a copy of Appendix D have access to these filtering facepieces (dust masks)?  For the…...

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Why is pressure decay not acceptable under ASME B31.3 or 31.5 for a leak test?

Pressure decay testing, monitoring a gauge for a pressure drop over a specified period, is unacceptable as a standalone leak test under ASME B31.3 because the code explicitly mandates a 100% visual examination of all joints and connections while the system is under test pressure. While a pressure decay test can indicate that a system…...

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Can I use compressed air to blowdown/purge my Natural Gas piping?

I am always amazed at the number of facilities that do not understand their hazardous materials and the proper safety techniques in managing the hazards these HAZMATs present. Recently I came acorss a sitution where a contractor was left to “prepare piping for a line break”. The facility utilizes natural gas, as a fuel, within…...

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Anhydrous Ammonia is a FLAMMABLE GAS

For the doubting Thomas (no offense to actual people named Thomas), here is a bit of info to BELIEVE… I can not believe I have to say this in the Year 2026, but: Anhydrous Ammonia is a FLAMMABLE GAS Look it up on any reputable SDS. Yes, it is shipped as a non-flammable gas, but…...

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Differences in the old “Wheat-Stone Bridge” technology with todays “Catalytic Bead” detectors

When comparing a Wheatstone bridge detector and a catalytic bead detector (often called a pellistor), it is essential to clarify their fundamental relationship: they are not competing technologies, but rather complementary components of the exact same industrial gas detection system. A catalytic bead sensor CANNOT function without a Wheatstone bridge circuit, and in the context…...

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Marking Hazardous (Classified) Locations

Marking Hazardous (Classified) Locations is a critical step in both compliance and personnel safety. While OSHA and the NEC (NFPA 70) mandate the classification of these areas, they are surprisingly quiet on exactly how to physically mark them. Because “invisible” hazards like flammable vapors or combustible dust can’t be seen, you should use a tiered…...

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OSHRC on “Universal PPE Hazard Assessments” at distribution centers

This is a very interesting AND disappointing decision by the commission.  They accepted a PPE Hazard Assessment done at a distribution center in AR for a facility in TX.  The business argued that the 100+ distribution centers around the country are identical with identical job functions.  The commission, although they state otherwise, appears to be…...

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Explaining the difference in “stress relieved during fabrication”, Cold-Formed Heads, and Hot-formed Heads (CGA 2.1)

In the world of pressure vessels (like those governed by ASME Section VIII), the terms “stress relieved during fabrication”, Cold-Formed Heads, and Hot-formed Heads relate to heat, but they are very different techniques used in PV construction. PWHT is about treating the material after it’s been worked, while “hot formed heads” is about shaping the…...

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OSHA’s Process Safety Management Standard is NOT the only standard that requires “verification of knowledge” after training

In the PSM/RMP world, the battle rages on with regards to “verification of knowledge” for those receiving training related to their work in, on and adjacent to a PSM/RMP covered process.  Yet for those safety professionals not working at a PSM/RMP facility, you too have a standard, that will just about cover ALL workplaces, that…...

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