OSHA has issued a 2022 LOI discussing the use of Transmitting bulk shipment labels by technological or other means. In the letter, OSHA addresses the use of QR Codes, which has become a very popular means of conveying information to employees. Here are the two (2) questions OSHA addresses in its letter: Question 1: Does […]
As we have discussed, the “note and exception” that goes with 1910.147(c)(4)(i) is what I call “simple lockout”; however, I have always stated it was intended for simple electrical lockouts, seeing how one of the hurdles to using the exception was that there could be no “stored energy.” So, when we look at the eight
We can change people’s performance by better training and instructions, better supervision, and, to some extent, better motivation.
The leaders of an organization MUST be the drivers of the proverbial “safety vehicle.” They steer and control the acceleration and braking. They also choose where they want the organization to go and enter that info into the vehicle’s GPS.
Having a functional and mature Safety Management System (SMS) is ALL about decision-making. Thus, the SMS must be a safety decision-making tool, unlike the traditional safety “programs” that are usually separate from business and operational decision-making.
The appreciation that a person makes of the situation depends mainly on the following four (4) elements:
There is NO exception in either 1910.146 or 1926.1201-.1213 for NOT having a rescue plan for “permitted entries” into a PRCS. There is an exception for the “Non-Entry rescue method,” BUT there is NOT one for having a rescue service readily available when the space being entered is a PRCS and the entry method is
On October 9, 2023, at about 11:30 a.m., three (3) technicians tasked with performing maintenance work in an underground fuel reservoir died after they entered the underground tank. All three died from suffocation. This tragic incident is like the many before! A single entrant entered the space and became incapacitated, leading his/her co-workers to go
I had the pleasure of teaching another Advanced Course on Process Safety (40-hr). When discussing Relief Systems, their design, and their RAGAGEP(s), the UPWARDS and UNOBSTRUCTED piece got many questions. ALL RAGAGEPs regarding PRDs will state “UPWARDS and UNOBSTRUCTED” or similar language. Even the older OSHA standards uses the phrase “Upward and Unobstructed” in the
Once we get to the place where we can agree that fluids and gases are “stored energy” and that those “stored energies” have to be bled/drained to achieve a Zero Energy State (ZES), we can then discuss the potential hazards these necessary actions can create. I have written a lot about using 1/4 turn ball
A few weeks ago, I shared my thoughts on whether a business was ready for a Behavior-based Safety process (BBSP). Since then, I have been asked what some “indicators” could be that a business is “culturally ready” for a BBSP. And for me, it can all hinge on how management EMBRACES NEAR-MISS gifts. Yes, near-misses
I am seeing a lot of disinformation regarding Behavior Based Safety, and of course, those dis’ing BBS have the latest and greatest approach to fix all your safety problems. But don’t be fooled. BBS is a tool in our safety toolbox and like any tool in the hands of UNTRAINED personnel, it can be misused
