Without a doubt, the biggest LOTO failure for businesses with a LOTO program is the application of the “minor servicing” exception. (emphasis by me) 1910.147(a)(2)(i) This standard applies to the control of energy during servicing and/or maintenance of machines and equipment.1910.147(a)(2)(ii) Normal production operations are not covered by this standard (See subpart 0 of this […]
I promise you; these are written in the blood of many who have perished – THEY ARE LOTO FACTS, and they are not wrong. If employers could grasp these simple facts, many limbs and lives could be saved yearly. The standard is called “The Control of Hazardous Energy”. It is NOT Lockout AND Tagout; it
Those in the USA have dealt with OSHA’s Process Safety Management Standard since 1992 and EPA’s Risk Management Plan since 1999. And although these standards established a well-needed MINIMUM performance criteria, they missed the market in what we come to expect in a proper performance-oriented standard. OUr friends to the North have been using an
The Process Safety Fundamentals (PSFs) are straightforward, doable best practices designed to raise awareness of process safety and spark conversations in the field. The PSFs can often be fully satisfied, but when they can’t, it’s essential to pause and hold a meaningful conversation with the team, supervisor, and support personnel to figure out a different,
Did you know there is actually some logic behind OSHA and NFPA’s Hot Work Permitting process? This means that even before we issue a HW Permit, we have to walk through this logic. In essence, if we can do the work WITHOUT having to perform HW; then by all means, we do the work without
It is important to note that preventive actions are not entirely the same for the different risk categories (minor, serious, or major): organizational failures generally play a much greater role in serious accidents than minor accidents. Indeed, a serious event usually implies the systemic failure of many barriers. The prevention of major accident hazards should,
It is important to note that preventive actions are not entirely the same for the different risk categories (minor, serious, or major): organizational failures generally play a much greater role in serious accidents than minor accidents. Indeed, a serious event usually implies the systemic failure of many barriers. The prevention of major accident hazards should,
In recent months we have seen some reductions in workforce across several clients. Some of these clients are very mature in their approach to safety management, and others are not quite there yet. In those businesses with a mature Safety Management System (SMS), one of these facilities is NOT a PSM/RMP facility – but they
Last week, I had an interesting discussion with a long-time client about the next steps in their safety evolution. While working with their safety team members out and about in the plant, we hardly see any violations, errors, or mistakes when auditing work permits and the like. But we are dressed like Christmas trees during
Q3. You ask whether the recertification (i.e., the requalification) requirements in 49 CFR Part 180 are applicable to stationary cylinder systems installed in a building and refilled by a third party. A3. The answer is yes if the cylinders are represented as meeting the requirements of the HMR. Section 180.3(a) states no person may represent
At 5:15 p.m. on October 27, 2013, three (3) employees and a supervisor were working on the deck of three (3) barges to ready them for delivery. The supervisor and one of the employees entered the #1 cargo tank of barges #1 and #2 to check the deep well blind on the deep well inspection
On January 20, 2017, Employee #1, 45, was tasked with removing a “Victaulic Blind Flange” on the inlet section of a 400-ton chiller held in place with a split collar. The machine had been idle for over four (4) months as it was winterized, with all electrical connections removed and locked out. The employee began
