This memorandum is intended to reiterate existing policy that allows Regional Administrators and Area Directors discretion to NOT GROUP VIOLATIONS in appropriate cases to achieve a deterrent effect. In particular, the agency may refrain from grouping violations where there is evidence that worksite conditions giving rise to the violations are separate and distinct, or where…...
The current Instance-by-Instance (IBI) policy, published in 1990, applies only to willful citations. OSHA believes that a more expansive application of IBI will incentivize employers to proactively prevent workplace fatalities and injuries and provide OSHA with another tool to use on its mission to ensure safe and healthful working conditions for America’s workforce. The scope…...
At 8:42 p.m. on February 19, 2022, Contractor #1 was taking apart an active heat exchanger. While doing this, 419 pounds of ammonia were released, causing upper body burns to an the contractor. Two contractors and one employee went to the hospital. The contractor was hospitalized for treatment. … Membership Required You must be a member...
Homer was a Greek poet who is credited as the author of the Iliad and the Odyssey, two epic poems that are foundational works of ancient Greek literature. Homer is considered one of the most revered and influential authors in history. But it is one of his very brief statements that most safety professionals can…...
Some consultants want to help you make your employees FEEL safe… #phsychologicalsafety I want your employees to feel what it means to actually be safe by the ABSENCE of FEELING PAIN from an injury/illness. Safety is FUNDAMENTALS, not a feeling or a mental state one has. I know many people who FELT like…...
I am always amazed at how far facilities will go to “exclude” contractors from their PSM/RMP contractor program. One that is a very common exclusion is “painting contractors”. Here is an example of how the WRONG painting contractor, provided with a bad scope of work, can cost you more than you bargained for…… Membership Required...
Back in my time, we could use phrases like “dumb as a post,” and people were not offended, and they clearly understood what you were trying to convey. I often think back to that statement when I think about bollards—such a simple, effective means to protect critical assets when designed and installed PROPERLY. Many seem…...
The existing PSM standard (1910.119) applies in part to processes involving a flammable liquid or gas on site in one location in a quantity of 10,000 pounds or more. However, the existing PSM standard contains an exemption for “[f]lammable liquids stored in atmospheric tanks or transferred which are kept below their normal boiling point without…...
The potential changes of scope include: Clarifying the exemption for atmospheric storage tanks Expanding the scope to include Oil- and Gas-Well Drilling and Servicing Resuming Enforcement for Oil and Gas Production Facilities Expanding PSM coverage and requirements for reactivity hazards Updating and expanding the list of HHCs in Appendix A of the existing PSM standard…...
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What are your thoughts on this approach? Why an overly detailed safety plan can be a liability A massive rulebook that most workers won’t read can leave a contractor vulnerable to fines and lawsuits, according to panelists at AGC’s safety conference. https://www.constructiondive.com/news/agc-panel-an-overly-detailed-safety-plan-can-be-a-liability/640854/ It seems we are on a merry-go-round of safety these days! I…...
As I have been writing about fundamental safety practices and how they play a critical role in OSH and Process Safety in the workplace, my views get pounded by the HOP and Psychological safety gurus. As I have said countless times, HOP and Psychological Safety have roles in a world-class safety management system; however, they…...
