Safety Info Posts

Fatal occupational injuries involving confined spaces (BLS July 2020)

From 2011 to 2018, 1,030 workers died from occupational injuries involving a confined space. The annual figures range from a low of 88 in 2012 to a high of 166 in 2017. Fatal occupational injuries involving confined spaces, 2011-2018 Year 2011 2012 2013 2014 2015 2016 2017 2018 Fatal work injuries 120 88 112 116…...

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OSHRC vacates fatal PRCS citations involving gasoline tank cleaning (OSHRC said it was “construction work”)

The company is a fuel filtration and tank cleaning company. In December 2014, an employee was found unresponsive and later died from gasoline inhalation while cleaning tanks at a construction site in Daytona Beach, Florida. Following the incident, OSHA conducted an inspection and issued an 11- item serious citation for violations of 29 C.F.R. ยง…...

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Routine and Non-Routine process openings and Chlorine

I do a lot of work in Ammonia and Chlorine, from process safety to emergency response, and the one thing I commonly get asked is why do I write so much about ammonia accidents and not so much about chlorine accidents.  Well, to be honest, the vast majority of my chlorine clients are much better…...

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Are you worried about a hydrostatic relief system discharging an HHC/EHS into an occupied space?

For nearly 25 years I have seen CLOSED relief systems used successfully on a multitude of processes involving Extremely Hazardous Substances (EHS) and for many years I have been proposing they be used in the Ammonia Refrigeration industry.  The leading trade group for ammonia refrigeration has had a long-standing position against the need for hydrostatic…...

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Hydrostatic Relief on piping systems – why so much hate?

We visit this topic once again as I have already spent time with a “former client” who is now in a serious bind with both OSHA and EPA after a significant Chlorine (Cl2) release.  They are a former client as they fired me after a 5-year PHA and 3-year audit a number of years ago. …...

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More COVID-19 safety and OSHA inspections (HAZCOM and Flammable Liquids)

This week I received a call from a client who had yet another visit from OSHA regarding COVID-19 complaints, but this time the CSHO was an experienced safety professional who peeled that onion back a few more layers and thus she was recommending a serious violation of HAZCOM related to the COVID-19 safety program.  What…...

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Grounding grids for emergency transfers of flammable liquids

Back in my HAZMAT days, we did a lot of transfers from damaged containers to proper containers to mitigate the release of hazardous materials.  When the HAZMAT was a flammable liquid, we oftentimes had to construct our own grounding grid.  This was more than not a massive challenge for us as we did this all…...

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Addressing Hazardous Area Electrical Installations (USCG)

The United States Coast Guard (USCG) has issued a Safety Alert to emphasize the importance of properly installed and maintained listed or certified safe electrical equipment in hazardous areas in order to reduce the risk of fire or explosion on board vessels. The publication follows an increasing number of instances by the Coast Guard where…...

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How high are your loading docks? (1910.28(b)(1))

This citation is what we call a “gimme” as this can be found at just about every workplace that has loading docks.  We have written this up many times during our S&H audits, only to get some lovely looks and compliments from the facility personnel.  Many seem to think that if the dock is only…...

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When 1926.64, OSHA’s PSM standard for Construction would apply

First, let me state that this construction standard has never been cited.  This is based on my personal knowledge and the OSHA database; however, it is still in effect and could be cited.  Last year, OSHA revised their standards and they simply did away with the duplicate language in 1926.64 and said to follow the…...

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More safety factors for flammable liquid safety systems – Inerting Systems

Many large scale processes that use Cat 1, 2, and 3 flammable liquids may also rely on a Nitrogen purge system to ensure the space within the process vessel is BELOW the Limiting Oxidizer Concentration (LOC) – sometimes called the Minimum Oxygen Concentration (MOC).  This safety system is based on the simple fact that if…...

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Don’t trust your SDS when working with your flammable liquids – NFPA suggest some safety factors be applied!

Many of us use Safety Data Sheets (SDS) on a regular basis and most of us have come to the realization that these documents fall far short of providing us the safety information we really need.  For example, when working with flammable liquids do you trust the SDS data to provide an accurate Flash Point…...

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