Safety Info Posts

OSHRC decision on Minor Servicing using an Interlock and Machine Specific Procedures

At its facility, Respondent converts paper products into finished products such as rolls of toilet paper and paper towels. The paper products are run through machinery operated by Respondent’s employees. One of these machines is the R74 Line Rewinder (Rewinder) machine. The Rewinder transforms a 10-foot by 10-foot giant roll of toilet paper into the…...

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The journey of the “lazy bollards” (what we call bollards that just don’t work!)

The Hydrant and PIV must be protected, so we installed two (2) “lazy bollards.” The post are correct, their installation is NOT to code. Had they been installed in the parking lot with a 15” diameter footing and at a height of 4’ AND 4’ away from the PIV, then all would be OK. But…...

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Manufacturer’s Limitations of Sulphur Sticks

In 2012, I discussed the use of sulfur sticks and asked a question: Sulfur sticks and ammonia leaks… are you in compliance when using these leak detection devices? In 2014, IIAR updated its edition of ANSI/IIAR 2 – Standard for Safe Design of Closed-Circuit Ammonia Refrigeration Systems, which PROHIBITS their use when charging is being…...

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Bypassing safety critical valves

In almost every PHA I have done since 2000, we find safety critical valves or instrumentation with a built-in bypass around them. I understand the need for a bypass WHEN IT IS FOR MAINTENANCE of the device, but in no sane world do we put a bypass around a safety-critical device so that the process…...

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OSHA issues PSM citations at ink and coatings manufacturing facility (Flammable Liquids & $183K)

The operators of a global ink and coatings manufacturing company could have prevented an employee from suffering burn injuries from a flash fire that erupted in an industrial mixing vessel containing flammable liquids and vapors by following federal regulations for handling of highly hazardous chemicals. An OSHA investigation determined a flash fire sparked in the…...

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OSHA’s Construction Standard for PRCSs information collection requirements

OSHA’s Construction Standard for PRCSs specifies several information collection requirements. The following sections describe who uses the information collected under each requirement and how they use it. Employers and employees would use these information collection requirements to identify a confined space at a construction worksite. The purpose of the information would permit employers and employees…...

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When you see it… (Bollards)

How many code/RAGAGEP violations can you identify? Tip: Code(s) and RAGAGEPs require equipment to be protected against contact with mobile equipment when that contact could lead to an LOPC event involving a hazardous material. Answer(s) below:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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[My] Weekly Safety Thought – Building an SMS is like building a house

Imagine trying to build a house today without the proper tools, such as a hammer/nail gun, handsaw/power saw, and tape measure. These are obviously critical to the task being done WELL and EFFICENTLY. Sure, we could build a house without them, but would it be one we would buy and put our family in for…...

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Weekly Safety Thought – The importance of Auditing, Inspecting, Observing, and Management Safety Contacts

In a mature Safety Process/SMS these four (4) elements play a critical role in delivering VALIDATED data to management so that the data can be analyzed and properly responded to in order to INTERVENE in the conditions/actions/attitudes BEFORE an event delivers undesired consequences. The late great Trevor Kletz said it best three decades ago in…...

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Weekly Safety Thought – The importance of Auditing, Inspecting, Observing, and Management Safety Contacts Read More »

Improving Safety at Facilities within the Pacific Northwest with Smaller Ammonia Refrigeration Systems (EPA RMP GDC)

While anhydrous ammonia has many environmental and operational benefits, it is also an extremely hazardous substance that, if accidentally released, presents a significant health hazard because it is corrosive to the skin, eyes, and lungs. Ammonia is also flammable at certain concentrations in air. The Environmental Protection Agency (EPA) would like to work with facilities…...

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Improving Safety at Facilities within the Pacific Northwest with Smaller Ammonia Refrigeration Systems (EPA RMP GDC) Read More »

EPA RMP GDC citations @ bulk storage facility (Flammable Liquids & $23K w/ $150K SEP)

Respondent is the owner and operator of a facility. Respondent operates a bulk liquid storage facility and offers a full range of heating, blending, and product services. Various products, such as vegetable oil, chemicals, and petroleum products, are received in tanks for storage and transferred out of the facility to customers. Some of the petroleum…...

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EPA RMP GDC citations @ bulk storage facility (Flammable Liquids & $23K w/ $150K SEP) Read More »

Do OSHA’s sanitation requirements apply to railroad track employees and roadway maintenance groups that are working along the tracks?

Today, OSHA posted its latest LOI.  This one was regarding railroad track employees and roadway maintenance groups and the need to provide sanitation facilities for these workers. Question: Do OSHA’s sanitation requirements apply to railroad track employees and roadway maintenance groups that are working along the tracks? Answer: Yes. Under section 4(b)(1) of the Occupational…...

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Do OSHA’s sanitation requirements apply to railroad track employees and roadway maintenance groups that are working along the tracks? Read More »

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