Safety Info Posts

Is a PSSR “necessary” for a Replacement in Kind (RIK)?

Notice I used the word “necessary” and not the word required.  In my experience, a PSSR saved my ass plenty of times when OSHA/EPA did NOT require it.  To my knowledge, OSHA (nor EPA) have defined the word “facilities” in the context they used it in 1910.119(i)(1)… (emphasis by me) 1910.119(i)(1) The employer shall perform…...

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EPA issues RMP & EPCRA citations @ food prcessing facility (NH3 & $650K)

The U.S. Environmental Protection Agency (EPA) and Justice Department have reached a settlement with a food processing company to resolve alleged violations of the Clean Air Act (CAA) and Emergency Planning and Community Right-to-Know Act (EPCRA) at the company’s food processing facility in North Kingstown, Rhode Island. The alleged violations pertain to chemical release prevention…...

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ANTI SLIP GRATING SAFETY STAIR NOSING – STEEL & COMPOSITE

I challenged a product recently on a LinkedIn post. My challenge was based on a video advertisement and caused me to question the product and what it could do to OSHA and IBC codes related to steps/stairs. One of the company reps, Rick Corbin, contacted me and gave me more information, and I stand corrected…....

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HVAC Contractor’s Scissor Lift causes NH3 release & fatality

At 11:09 a.m. on December 19, 2022, an HVAC contractor was installing a heating unit when a coworker operating a scissor lift struck a NH3 pipe/valve that caused a release of ammonia. The contractor, 68, was overcome by ammonia and died.  The lift operator was hospitalized for treatment for his exposure to ammonia…. Membership Required...

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Testing your unsupervised fire alarm (sweating the small stuff)

One of the audit findings that we believe to be an essential requirement certainly raises many folks’ blood pressure.  We get accused of “piling on” when we write up findings in our OSH and PSM/RMP audits regarding the incorrect testing of a facility’s employee alarm system(s).  And we use OSHA’s requirements, which are actually quite…...

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NIOSH – Revocation of Public Health Emergency (PHE) Approvals issued during the COVID-19 Response

Between May and November 2020, the National Institute for Occupational Safety and Health (NIOSH) issued limited, temporary Public Health Emergency (PHE) approvals for N95 filtering facepiece respirators (FFRs) and powered air-purifying respirators (PAPRs) to address respirator supply shortages during that time. In July 2021, NIOSH published NIOSH CA 2021-1036 to remind PHE approval holders that these…...

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The ins and outs of PPE training

There was some legal advice given today on a social media site regarding documenting our safety training with sign-in sheets, so if OSHA ever asked for records to show an employee was “trained”, the employer would be able to show the sign-in sheet.  The advice even contained the statement: Your safety training in this respect…...

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LOTO programs and the SECONDARY SECUREMENT of large objects

Today’s MSHA Fatality Report made me wonder how many LOTO programs require the SECONDARY SECUREMENT of large objects, even after the power source that normally moves the equipment has been locked out.  For example, cooling towers and condenser fan blades. I have experienced firsthand a piece of equipment two times involved were very large fan…...

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The Heat Index is a hell of a lot more than simply “what it feels like” outside

The heat index is based on the relative humidity.  When this relative humidity is HIGH, it significantly reduces the ability of our sweat to evaporate off our skin.  This sweating and evaporation process is how our bodies are cooled.  Our Heat-Related Illness Prevention Plan’s “action temperature(s)” MUST be based on the HEAT INDEX – not the…...

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Chlorine Institute has updated its A, B, and C Kit manuals

The Chlorine Institute has updated its A, B, and C Kit manuals with some significant revisions.  Unfortunately, these manuals are no longer free to non-members, but if you utilize these kits in your emergency response program, they are a MUST-have.  Luckily they cost only $40.  Here is a peek at the B-Kit Manual revisions:… Membership...

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Natural Gas Excess Flow Valves on Residental Feeds

Today I saw our local Natural Gas service provider discussing installing an Excess Flow Valve with my neighbor.  So naturally, that caught my ear, so I mossed over to learn more.  It seems that most Natural Gas service providers are offering the installation of an Excess Flow Valve on the feed to homes.  Of course,…...

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Safety Thought of the Week… Administrative Controls form a major part of any hazardous system’s defenses

It has become fashionable to claim that human error is implicated in 80-90 percent of all major accidents. While probably close to the truth, this statement adds very little to our understanding of how and why organizational accidents happen. In the first place, it could hardly be otherwise, given the range of human involvement in…...

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