Safety Info Posts

Vent & Burn @ East Palestine Derailment

The derailment in East Palestine, OH, was a classic need for a Vent & Burn operation (as shown in the video).  There was some indication that one or more of the Vinyl Chloride railcars had begun its polymerization reaction, which could result in catastrophic consequences for many people and property.  This indication also eliminates the…...

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Unsafe Hot Work strikes again ($1.5M in damages)

On May 3, 2022, at about 19:45 local time, the inspected passenger vessel Natchez, with one crewmember on board standing a security watch, was moored in the Industrial Canal in New Orleans, Louisiana, undergoing renovations when a fire broke out.1 Local firefighters extinguished the fire at 2139. No pollution or injuries were reported. Damage to…...

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Non-Conductive Flammable Liquids and filling non-conductive containers

Filling or handling plastic or other non-conducting containers can still be hazardous when the flammable liquid is conductive. The splashing (filling) and turbulence of the liquid in the container can cause a static electric charge to build up in the liquid or on conductive parts of the container that are not adequately grounded. A spark…...

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Grain Coop issued Willfuls after worker lost leg inside silo

SPECIAL NOTE: This appears to be the first case where OSHA has applied it’s new Instance-by-Instance Penalty for Willful Citations.  This case involved a leg amupation while working inside a sile with the paddle conveyor still running.  OSHA issued three (3) Willfuls using 1910.28(b)(6)(i) for each citation and all three (3) were willfuls. An grain…...

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Be careful what we ask for in our SOPs and SWPs

When writing SWPs/SOPs be sure how you phrase things. KNOW your audience. An elementary teacher got what she asked for when she simply asked the class to draw a clock showing the time as 10 minutes past 11. This exercise is called the Clock Drawing Test for Cognition. Usually reserved for the elderly or someone…...

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EPA RMP Citations @ manufacturing facility (Flammable Gases)

This case is significant as EPA used the International Fire Code as their basis for several General Duty Clause findings.  They also used NFPA standards in their inspection. Respondent owns and operates a facility that manufactures consumer and industrial products in liquid form and for pressurized containers that use aerosol propellants. Respondent’s manufacturing process uses…...

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Inspections and Audits – their roles and differences

A recent FaceBook post by the South Dakota Highway Patrol is getting a lot of attention. The pics are alarming, to say the least. But some of the comments are an indication of where safety stands in the United States culture of safety.  When people decry government intervention as “crossing a line,”… “that truck driver…...

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Did OSHA miss the opportunity to improve safety around PRCSs?

In OSHA’s LOTO standard, they incorporated a requirement that required businesses to have forethought about the means used to isolate energy.  Specifically, the standard requires: 1910.147(c)(2)(iii) After January 2, 1990, whenever replacement or major repair, renovation or modification of a machine or equipment is performed, and whenever new machines or equipment are installed, energy isolating…...

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Understanding statistics in public relations

Since the train derailment in Palestine, OH, on February 3, many have heard the statistic… More than 99.98% of rail hazmat shipments reach their destination without a release caused by a train accident. Source: https://www.aar.org/wp-content/uploads/2020/10/AAR-Hazmat-Fact-Sheet.pdf That statistic may very well be accurate; however, without understanding the definitions used, there could be some padding in the…...

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Viewing Lockout/Tagout thru the lens of a Safety Management System

Last month I wrote a few posts about how a compliance manual made up of dozens of individual safety programs written for OSHA compliance needs is not a safety management system (SMS).  That post got a lot of friends to encourage me to expand on that position and explain what I meant.  So using one…...

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The “Hierarchy of Controls” in the Year 2023

A lot has changed over my career; some things I thought were so concrete and fundamental to OSH that they would never change.  Boy, was I ever WRONG!  Take, for example, the “hierarchy of controls” – quite possibly the primary building block of OSH and Industrial safety for the past 73 years.  When I was…...

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ATV’s present unique hazards to workplaces (Active Failures and Latent Failures)

ATVs, commonly called 4-wheelers, have been around for decades.  Most people recognize the risks associated with these machines outside of the workplace.  The accident/injury statistics can be alarming.  But when management claims those accident statistics are not work-related and that somehow the risks these machines pose are less in the workplace may be a very…...

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