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
At 1:00 a.m. on January 19, 2019, Employee #1, 45 years old, employed by a plumbing company, was working at a refinery. He was removing a blind flange in preparation for installing 2-inch piping to a 2-inch line in the MHF Alkylation unit. When the flange was unbolted…
At approximately 4:00 a.m. on March 29, 2020, an employee, 30, was installing a full face blind on a flange on a reactor. Then, the probe stem fell inside of the reactor, and the employee tried to fish it out. Using a Jacobs ladder, the employee entered the unprepared reactor that was not cleared for
At 1:30 p.m. on July 24, 2020, two employees were reconnecting two (2) 2″ flanged pipes after cleaning the 4″ header. The employees were beginning to unbolt the blind on the last pipe to reconnect it to the header when…
At 1:15 p.m. on November 3, 2020, Employee #1, employed by an HVAC company, was working at a customer’s commercial facility. He was in the process of removing a coupler and blind from the intake header of an air dryer. The employee did not first relieve the air pressure from the header.
OSHA answers the following questions regarding maintenance and servicing tasks where Cathodic Protection (CP) rectifiers protect pipes against corrosion. Question 1: Is LOTO of a CP rectifier required when working on a pipeline? Question 2: Is the use of a metallic bonding cable an acceptable practice in lieu of CP rectifier lockout/tagout? Background: Cathodic Protection
Nowadays, most machines/equipment come equipped with a digital HMI screen(s) rather than the old-fashioned “Start/Stop” buttons. Most see this as an improvement in using technology. However, for those with “machine specific” LOTO procedures, these HMI screens pose a challenge regarding “verifying ZES” for the electrical energy sources. In the old days, we returned to the
“Kick Up The Arse” – KUTA principle Here is the rule Comply with the rule Enforce the rule Punish people who don’t comply Put a cop on every beat and police the rule We’ll catch you and watch out. Results? No ownership, limited maturity, and reporting goes “underground.” This thinking drives a “nanny” mindset: power
