Safety Info Posts

SIF can be transformational when it is the right time to make the move

The client this week had such an eye-opening experience with the risk assessment yesterday; they were all early this morning and had written out their homework assignment for the night! We took their loading docks and did the OSH version of LOPA called a Hierarchal Analysis around workers being crushed by a trailer at the…...

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Why is safety so difficult to manage?

As safety pros return to work this week from the annual ASSP conference last week, their excitement and enthusiasm will either blossom or bottom out.  So many new techniques are being pushed in the safety arena these days, and many safety pros and management personnel are grasping for whatever it takes to turn their safety…...

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Fatal flaw in OSHA’s “Periodic Inspection” requirements

We are all familiar with OSHA’s LOTO Periodic Inspection requirements (1910.147(c)(6)).  It is a topic of great debate, still in the Year 2023.  But there is a serious, I say it is a fatal flaw in the periodic inspection process. It is common for this activity to be performed by managers/supervisors who are authorized in…...

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KY-OSHA and the application of it’s PRCS standard for Construction

When people say, “safety is just common sense,” I wish we could slap them.  Working for a client in KY, I have identified so much that is different between their state plan and the federal OSHA requirements.  Some of the differences just do not make sense and I am sure there are some political forces…...

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KY-OSHA 1st Aid Standard is very different from 1910.151

As with some state plans, KY-OSHA has some standards that are more in-depth than the federal version.  Although, a couple of years ago, the KY legislature passed a bill that restricts KY-OSHA from adopting any standards that are more stringent than federal OSHA.  But for now, KY-OSHA’s 1st Aid standard goes much further than federal…...

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KY-OSHA’s Stop Work Authority Standard

Where an employee is confronted with a choice between not performing assigned tasks or being subjected to death or serious injury arising from a dangerous condition at the workplace, such employee may refuse in good faith to expose himself/herself to the dangerous condition. The condition causing the employee’s apprehension of death or injury must be…...

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Kentucky’s Hazardous Liquid Unloading standard

A “Hazardous liquid” means, for the purpose of this regulation, a chemical or mixture of chemicals that is toxic, an irritant, corrosive, a strong oxidizer, a strong sensitizer,combustible, flammable, extremely flammable, dangerously reactive or pressure generating or which otherwise may cause substantial personal injury or substantial illness during, or as a direct result of any…...

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KY OSHA does not allow Tagout when the device can take a lock

I am not trying to start another LOTO fight about Lockout vs Tagout, but for those who do work in the state of KY, it is important to know that KY-OSHA does NOT allow an employer to utilize TAGOUT when the device can accept a lock.  This is different than what Federal OSHA allows.  Federal…...

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Visual Demo of “Work as Imagined” vs “Work as Done” (safety fencing modified)

Recently I was working with a client on some LOTO procedures, and I was out, and about in the plant, and as I was tracing down an airline, something caught my eye.  At first, I was not sure if I was just seeing things, as in my safety mind, there was just no way anyone…...

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Does a PSV have to be replaced after it lifts?

I grew up under the belief that when a PSV lifts, it gets replaced ASAP. However, this practice seems to have changed over the years. So lets see what our RAGAGEP says on the matter…… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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OSHA’s PSM and EPA’s RMP standards are a great start for a SMS – but need more than cut & paste

One of the things that EPA learned from OSHA’s roll-out of their PSM standard was that not everyone recognized the standard as a 14-element management system.  So when it came time for EPA to roll out its RMP, they made a “management system” part of its requirements.  However, EPA quickly disappointed when they said all…...

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PRCS entry “hoisting system” (1926.1203)

Recently we were performing an evaluation of a facility’s Confined Spaces and assessing if any were Permit-Required Confined Spaces and we came across this space.  I immediately knew that the winch was NOT intended for personnel and was installed for pulling the pumps in this lift station. However, my escort, the facility safety person (and…...

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