Recently, I had the pleasure of touring the flagship facility of one of my original supporters of SAFTENG. The safety pro is a world-class leader and a fine safety engineer. When he arrived at this facility, he and the PM decided to rid the workplace of all the “safety banners.” Most had become eye-sores, some…...
Which establishments are covered by the update to the HCS? The scope and framework of the HCS have not changed with this rulemaking. Chemical manufacturers and importers are still responsible for providing information about the hazards of chemicals they produce or import. All employers with hazardous chemicals in their workplaces continue to be required to…...
Questions & Answers for OSHA’s Update to the HCS Final Rule Read More »
#1 If an employee presents a work status that indicates they are able to perform restricted work or light duty work yet we do not have work available that meets the restrictions, should we enter the number of days under “On Job Transfer or Restriction” or “Away from Work?”… Membership Required You must be a...
OSHA Recordkeeping Updates Read More »
Respondent operates a facility that produces glass-to-metal seals and high-temperature co-fired ceramics for use in semiconductor products. The Facility is located just over half a mile from a residential neighborhood; just under three-quarters of a mile from a charter school; just over three-quarters of a mile from a church and a skating rink; less than…...
I am just getting into Carsten Busch’s book The Heinrich Project III and it has already made it onto my top 10 list for safety pros. Carsten put together all of H.W. Heinrich’s articles and speeches from when he was with Traveler’s Insurance. If you are a believer, as I am, in many of the…...
Defending H.W. Heinrich – The Accident Pyramid Read More »
There has been a lot of public debate about OSHA’s attempt to update its emergency response standards. And in this debate there has been a lot of misinformation shared across municipal and private fire brigade groups in what OSHA is actually trying to implement. This document, from OSHA, is a compilation of the questions posed…...
QUESTIONS AND ISSUES COMPILED FROM THE EMERGENCY RESPONSE NOTICE OF PROPOSED RULEMAKING Read More »
Respondent operates a facility to manufacture chlorine, bleach, and hydrochloric acid. At all times relevant to this CAFO, Respondent produced, used, or stored more than 2,500 pounds of chlorine at the Facility and was subject to the requirements of CAA § 112(r)(7). At all times relevant to this CAFO, Respondent produced, used, or stored hydrogen…...
Recently, I had the pleasure of working with one of my international clients at several locations. This is in thanks to Paul A. for putting his trust in me throughout my career. Paul and I met in Omaha, NE, in the late 90s and formed a professional and personal friendship as he is ALL ABOUT…...
What a delight to hear a CEO and COB talk about safety in the right way Read More »
Much of my work involves helping clients achieve more than “compliance” with minimum government standards. I typically do this using RAGAGEPs; however, those may be too much to handle in some situations. So, I will propose another government standard that applies to the process/hazard. For example, unloading flammable liquid railcars. Canada has some of the…...
Railcar Loading and Unloading operations (Canada) Read More »
This is safety satire on a Friday afternoon after a long week! I may not be a Certified Welding Inspector (CWI) or a Visual Level II inspector certified per ASME V Supplemental NDE Certification requirements. Still, I believe API 570, Section 8 Repairs, Alterations, and Rerating of Piping Systems allows only a dozen or fewer…...
May be a bit out of spec for API 570 Read More »
From OSHA’s summary of the Final Rule: Heating, Air-conditioning, & Refrigeration Distributors International (HARDI) asked OSHA to update its Process Safety Management standard (PSM), 29 CFR 1910.119, to reflect this change once this rule is finalized (Document ID 0355, p. 2). HARDI’s comment is out of scope for this rulemaking, which pertains solely to updating…...
OSHA’s HAZCOM Final Rule and PSM Read More »
OSHA is amending the Hazard Communication Standard (HCS) to conform to the United Nations’ Globally Harmonized System of Classification and Labelling of Chemicals (GHS), primarily Revision 7 (Rev. 7), address issues that arose during the implementation of the 2012 update to the HCS, and provide better alignment with other U.S. agencies and international trading partners,…...
OSHA publishes its Hazard Communication Standard Final rule Read More »
