Recently a trade organization issued a guide on working in Permit Required Confined Spaces specific to their industry. The organization took a sentence from NFPA’s Guide on Confined Spaces (NFPA 350) and used it as justification to circumvent OSHA’s minimum standard on entry into PRCSs (1910.146 and 1926.1201-.1213). l have received over a dozen questions […]
As stated in REGO’s Warning Document… Simply retesting pressure relief valves manufactured by RegO that have been in service for several years to confirm conformance with start-to-discharge and reseal ranges does NOT guarantee that the valve is suitable for continued service. Or that the valve will perform as designed at nominal pressures or in emergency
“Relief valves should be inspected each time the container is filled but no less than once a year. If there is any doubt about the condition of the relief valve, it must be replaced.” Major Factors to determine the “Life” of Relief Valves include: Water/Ice Accumulation Corrosion Dirt – Debris Damage Normal Aging Eye protection
The old debate has been settled by the largest provider of LEVEL A suits. Many organizations store their emergency response gear in a trailer that is parked (usually) outside on the property. Although OSHA does not mention this level of detail, the manufacturer has now established the maximum temperature at which their suits may be
In a recent discussion regarding an accident with a Fuel-Oxy Torch system, I had some discussions about the layers of protection and the Prevent-Protect-Mitigate safety model using the Hierarchy of Controls (Elimination, Substitution, Engineering Controls, Administrative Controls, and PPE). The event did NOT involve a flash-back, but I used the flash-back requirements to demonstrate the
At 3:10 p.m. on February 2, 2022, an employee, 26, was performing maintenance on a System Applicator. The employee began the ammonia bleeding procedure wearing safety glasses and rubber gloves. After approximately 20 to 30 minutes, the employee no longer heard a whistling sound and believed that the system was completely bled out. When the
On February 19, 2022, Employee #1 took apart an active heat exchanger. While doing this, 419 pounds of ammonia were released, causing upper body burns to the employee. The employee was hospitalized for treatment.
It seems the games may never end with HFO-1234yf and it’s designation as a Highly Hazardous Chemical (HHC) within the Process Safety Management Standard. A friend of a friend in the automobile manufacturing industry contacted me about their use of this new refrigerant. The friend/client shared all of my previous articles explaining how HFO-1234yf is
A fine example of how the safety profession has drifted from science is the vast misunderstanding of hazardous gases. From their hazards to their behaviors, we have a lot of myths and misconceptions about hazardous gases. Sadly, the fact that OSHA does not have a “flammable gas” standard plays a role in this situation –
When workers say to me, “that hardly ever happens” I just shake my head. It happens far more often than most people think. I mean, think about why did OSHA promulgate the LOTO standard – people were turning on machines with workers inside. But this case was exceptionally bad! A father found his son inside
In this month’s CT-OSHA Safety Newsletter, the agency is pushing the ANSI Z358.1–2014 standard as their baseline EW/SS enforcement standard. The entire newsletter, which you should sign-up for, is dedicated to EW/SS’s and is full of great info. I am not a lawyer, but I do not think they can enforce a consensus standard that
The April 2022 incident that was reported as “two (2) men down on the property” was actually a PRCS accident involving a railcar at the repair facility. IN-OSHA released its findings last month and issued $113,400 to the business. One worker passed away, and the other survived. Here is a breakdown of IN-OSHA’s PRCS citations:
