Yes… here we go again! If we wish to claim an Excess Flow Valve as a “layer of protection” against a hose/pipe failure, we then MUST ensure the device is SIZED properly, INSTALLED properly, OPERATED properly, and MAINTAINED properly. This is what is called process safety management and for the life of me, I just […]
The Emergency Response Guidebook (ERG) 2020 is finally here! We’ve listed the most important changes from the 2016 edition to the 2020 edition. They’re listed based on the color of their section in the guidebook. White Pages:
On or about January 11, 2020, employees engaged in performing cleaning and maintenance on a heater treater system with a combustible engine power washer within range of flammable material stored within the heater treater were exposed to burn hazards.
I am going to guess that the facility’s inventory was less than 10,000 pounds of Propylene as OSHA issued no PSM citations, only a HAZCOM training citation and a GDC citation for four (4) issues they found with how the flammable gas was managed. Another incident showing OSHA’s weakness with “flammable gases”; they NEED a
One of the more popular findings in our LOTO assessments/audits involves the lack of specific procedures for verifying a zero energy state (ZES) for EACH energy source. The LOTO standard, 1910.147, makes it clear that the energy control procedure must be “specific.”…
As the debate continues to rage regarding the types of PRCS rescue and when they are required, OSHA has seen fit to publish the following: (emphasis by me) Effective emergency planning is vital to ensure that any entrant who becomes sick or is injured in a permit space can be evacuated quickly and safely. The
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
