This a followup to my earlier posting about OSHA LOI and using both Reclassifications and Alternate procedures on the same space at the same time. I received a lot of questions from that post so I thought I would share the info I shared with those who contacted me. This information is also directly from…...
It is important to understand that the temporary enforcement guidance memoranda do NOT offer blanket waivers or exemptions for complying with any OSHA standards or provisions of such standards, including the Respiratory Protection standard (e.g., annual fit-testing requirements). Rather, they allow for enforcement discretion by CSHOs during the COVID-19 pandemic period in circumstances where an…...
Jonathan Zimmerman and I received some less than flattering feedback when I stated in our 2019 ASSP presentation that there are NO exemptions for NOT having a rescue plan for ENTRY RESCUE when the entry method is via a “permit” (1910.146 (d)-(k). This single topic garnered more discussion after our session than any other –…...
We have had many discussions on SAFTENG regarding pressure vessel safety, but it is the Year 2020 and we need to have a very direct talk about how we manage flammable liquids and combustible materials around our pressure vessels. In this article, I am primarily speaking to those in the Anhydrous Ammonia fertilizer industry and…...
UPDATE from OSHA case file: At 12:30 p.m. on February 20, 2020, Employee #1, employed by a structural steel fabricator and erector company, was entering a tank to clean it. The tank had a combination of Ecocure II and methyl ethyl ketone (MEK) residues and had been purged with nitrogen. Employee #1 entered the permit-required…...
Disclaimer: I am not a fan of certifications and I carry NONE – a proud safety rebel who has bucked the certification wrap my entire career, so consider the source of this advice. Rather than spending hundreds of hours preparing for the ASP/CSP/OSHT/CSHT/CHMM/CIH how about taking a training course or two from a REPUTABLE provider…...
If you are an NH3 distributor and you’re using the Nitrogen Stabilizers some things have changed that you need to be aware of. First and foremost, see my posting with the Safety Alert from Transport Canada regarding the issues they have found regarding storage and transport tanks and these Nitrogen stabilizers. I have not heard…...
We have all seen it… the person assigned to be the PRCS Attendant (and Fire Watches suffer this infliction as well) are the youngest, weakest, least trained, least experienced, lowest paid, and most incapable person on the job/team. As I have written about before, one of my former employers actually but an age restriction on…...
In 2017 and 2019 I wrote about these Nitrogen Stabilizers and how their introduction into a PSM/RMP covered process would require a MOC and PSSR and I broke down the potential concerns and questions regarding these additives. Now it seems there may be a Mechanical Integrity twist to the use of these additives, as Transport…...
OSHA published a Letter of Interpretation making it clear that we can use “alternative entry” methods such that when the physical hazard(s) can be ELIMINATED OR ISOLATED through engineering controls, AND any atmospheric hazards can be CONTROLLED through forced-air ventilation and continuous atmospheric monitoring, the space may be entered using the alternate procedures set forth…...
Most have seen a full-face Air Purifying Respirator (APR), but just so we are on the same page, I have shared an image of a FF-APR. The serious question I have is… Can this FF-APR be equipped with “escape only” cartridges and be declared an emergency escape respirator? I so NO, but I will be…...
In the past 2-3 years, I have begun seeing Anhydrous Ammonia systems that claim to be built to ANSI K61.1 or CGA 2.1, but somehow these processes do not have the Emergency Shutdown Systems required by these two Recognized and Generally Accepted Good Engineering Practices. So with the help of the Illinois Fertilizer & Chemical…...
