Your letter discusses concerns with the safety of compressed gas cylinders on some types of portable carts configured for “in use” or “connected for use.” Specifically, you mention that cylinders, which are top heavy and therefore can be unstable (unbalanced), are commonly found poorly secured to the cart and leave the cylinders susceptible to toppling […]
After 30+ years of OSHA’s PSM standard (1910.119), we still come across far too many businesses that just do not understand the difference between the “INVESTIGATION” and the “CASUAL ANALYSIS.” I use this image from my training course(s) to help them differentiate between the two INDIVIDUAL and SEPARATE steps in the Incident Investigation element (1910.119(m)).
1910.165(b)(3) The employee alarm shall be distinctive and recognizable as a signal to evacuate the work area or to perform actions designated under the emergency action plan. After an employee becomes aware of an emergency situation, the next step involves actions to be performed by that employee. Generally, the actions include evacuation or emergency
My Dad had my brother and I set goals in our lives when we turned 16 years old. Financial, Professional, etc. At 16, we were too young to understand any of it, but he got us thinking. By 18, we started to have an idea of what we wanted when we “grew up”. Take for
I’m not asking for much, but before I leave this great and honorable profession, I just hope we can GET BACK TO THE FUNDAMENTALS! A great place to start would be to eradicate all these “Worked ____ Days” signs and progress to celebrate what got us those injury-free days. As I have said for decades…
Did the 2024 edition of NFPA 77, Recommended Practice on Static Electricity establish a norm for “relaxation time”? In six (6) different sections across five (5) chapters, the recommended practice cites “30 seconds” as a “suitable precaution.” (emphasis by me)
How many of you have thought these two images would ever have a place in Process Safety? I use them as visual aids when teaching some of my RAGAGEP courses, as they place a mental image that most can grasp into the students’ heads and provide them with a valid engineering metric they can
Have you ever read a RAGAGEP and wished you had been a fly on the wall in the room where a particular requirement was presented and debated amongst the committee members? I have set on my fair share of RAGAGEP committees over the past 20 years and in almost all of muy experiences, when someone
As we continue to “dumb down” RAGAGEPs to take away OSHA/EPA’s ability to cite fundamental engineering failures found in processes handling HHC/EHS, the issue of “conflicting requirements” continues to be troubling. As my Anhydrous Ammonia clients learned firsthand last year, with the 7th edition of CGA 2.1, the RAGAGEP has some NEW requirements for pressure
The 2024 edition of the International Fire Code has a new “table” that lists several exemptions. These exemptions come with some limitations, such as… Exempted materials and conditions listed in this table are required to comply with provisions of this code that are not based on exceeding maximum allowable quantities inSection 5003. Here are a
This was NOT intended to be directed at safety, but damn, if we look at all 13 through the lens of “barriers to world-class safety,” they sure do resonate. I have bolded my Top 3; which are your Top 3? 13 Brutal Truths Every Employer Needs to Know:
Both OSHA and EPA require PSM/RMP facilities to include procedures for “responding to small releases” in their Emergency Action Plans 1910.119(n) Emergency planning and response The employer shall establish and implement an emergency action plan for the entire plant in accordance with the provisions of 29 CFR 1910.38. In addition, the emergency action plan shall
