Safety Info Posts – Page 104 – Safety Engineering (SAFTENG)

OSHA will allow the use of the NHANES age-correction data for the creation and use of age-correction tables other than the ones in Appendix F under certain conditions

August 24, 2024 / Free, OSHA Compliance / Bryan Haywood

OSHA’s current age-correction table, Appendix F, discontinues at age 60. More people are working into their sixties instead of retiring, and there is no adequate way to assess presbycusis (age-related hearing loss) in these workers using the current OSHA table. OSHA’s age-correction tables were based on a small sample size and research from the 1970’s. […]

Training requirements for on scene incident commanders in OSHA’s HAZWOPER standard

August 24, 2024 / Emergency Response, Free / Bryan Haywood

OSHA clarifies HAZWOPER training requirements for on-scene Incident Commanders and other positions in the Incident Command System (ICS) and whether previous non-HAZWOPER training can be credited toward the training required by HAZWOPER for Incident Commanders. Here are the four (4) questions OSHA discusses: Is it OSHA’s intent that Incident Commanders be 24-hour HAZWOPER trained, irrespective

Should we STAMP and Sign each official PSM/RMP report?

August 23, 2024 / Chemical Process Safety (PSM/RMP), Free / Bryan Haywood

A client recently underwent an RMP inspection by the US EPA. One of the issues the inspector took issue with was that the facility did not “certify” their 3-year audit. This stems from the following: (emphasis by me) EPA RMP § 68.79 Compliance audits(a) The owner or operator shall CERTIFY that they have evaluated compliance

A Step Change in a facility’s Process Safety Management System

August 23, 2024 / Chemical Process Safety (PSM/RMP), Free / Bryan Haywood

It is 2024, 32 years after OSHA passed its Process Safety Management of Hazardous Chemicals standard. I am fortunate to have clients who have progressed in their PSM maturity, and we spend a lot of time these days working to get other processes into the PSMS. We start with processes that are not covered because

MI-OSHA enforcement position on PRCS rescue attempts

August 21, 2024 / Free, Permit Required Confined Spaces / Bryan Haywood

This ONLY applies to Michigan workplaces, but it was such a weird way to enforce the PRCS standard that I thought it was worth sharing. Keep in mind that more than 50% of PRCS deaths are “would-be rescuers.” Rescue Operations MIOSHA has no authority to direct rescue operations. This is the responsibility of the employer

The State of Missouri seeks to be the “delegated enforcement authority” for NH3 RMPs

August 21, 2024 / Chemical Process Safety (PSM/RMP), Free / Bryan Haywood

This rulemaking requires the Air Conservation Commission to develop a state rule and accept delegation from the EPA. This rulemaking will lay the groundwork for the Agricultural Anhydrous Ammonia RMP Compliance and Enforcement program. Once delegated, the oversight for the RMP program will transfer from EPA to DNR. The benefit of this rulemaking affects the

OSHA’s progress in revising the PSM Standard

August 20, 2024 / Chemical Process Safety (PSM/RMP), Free / Bryan Haywood

The Occupational Safety and Health Administration (OSHA) issued a Request for Information (RFI) on December 9, 2013 (78 FR 73756). The RFI identified issues related tomodernization of the Process Safety Management standard and related standards necessary to meet the goal of preventing major chemical accidents. OSHA completed SBREFA in August 2016. OSHA held a stakeholder

A great tool to assess your current SMS

August 18, 2024 / Free, Safety Management System / Bryan Haywood

You can assess your own health and safety management system using this self assessment checklist (.doc) . Use the columns in the middle of the table to give yourself a score for each element. Where you give yourself a score of 1 or 0 you may need to take action to improve those elements –

Managing Organizational Changes

August 18, 2024 / Chemical Process Safety (PSM/RMP), Free / Bryan Haywood

All changes to an organizational structure or changes in personnel with specific Knowledge, Skills, Experience, and Behaviors (KSEB) must be assessed to understand the impact of the organizational change on safety. Any organizational change has the potential to introduce safety hazards and risks, and therefore, all changes to an organizational structure or changes in personnel

Managing Changes using the “Plan, Do, Check, Act” management system approach

August 18, 2024 / Chemical Process Safety (PSM/RMP), Free / Bryan Haywood

The systematic process to manage any change should follow the “Plan, Do, Check, Act” approach. This should start at the planning stage BEFORE: the change has been fully developed, continued and monitored during the change process and reviewed after it has been implemented. This systematic approach applied to all changes to equipment, infrastructure, policy, or

Time Frame to Submit RMP Emergency Contact Information Changes

August 18, 2024 / Chemical Process Safety (PSM/RMP), Free / Bryan Haywood

How much time does the owner or operator of a stationary source have to submit a correction to a Risk Management Plan when the emergency contact information changes?

Safety Thought of the Week… LATENT ORGANIZATIONAL failures and accident causation

August 18, 2024 / Free, Motivational Safety Materials, Safety Management System, Safety Thought of the Week / Bryan Haywood

It is suggested that LATENT ORGANIZATIONAL failures are analogous to the “resident pathogens” within the human body, which combine with external factors (stress, toxic agencies, etc.) to bring about disease. Like cancers and cardiovascular disorders, accidents in complex, defended systems do NOT arise from single causes. They occur through the unforeseen (and often unforeseeable) concatenation