Safety Info Posts

Counterfeit Filtering Facepiece Respirators are posing an additional Risk to Healthcare Workers during COVID-19 Pandemic (American Journal of Infection Control)

/ Respiratory Protection /

Several cases of counterfeiting have already been reported. The Center for Disease Control and Prevention (CDC) has listed out some suspect characteristics of counterfeit respirators. Table 1 below summarizes the main suspect characteristics of counterfeit compared to appropriate FFR.  Among the suspect features, there are ear loops designs, the absence of markings or references to…...

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OSHA Discretion in Enforcement when Considering an Employer’s Good Faith Efforts During the COVID-19 Pandemic

/ OSHA Compliance /

In light of the coronavirus disease 2019 (COVID-19) pandemic, OSHA understands that some employers may face difficulties complying with OSHA standards due to the ongoing health emergency.  Widespread business closures, restrictions on travel, limitations on group sizes, facility visitor prohibitions, and stay-at-home or shelter-in-place requirements may limit the availability of employees, consultants, or contractors who…...

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EPA UPDATES their RMP GDC guidance (April 2020)

/ Chemical Process Safety (PSM/RMP) /

Under the Clean Air Act Section 112(r)(1), the General Duty Clause states: “The owners and operators of stationary sources producing, processing, handling or storing such substances [i.e., a chemical in 40 CFR part 68 or any other extremely hazardous substance] have a general duty [in the same manner and to the same extent as the…...

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The 8th Revision of the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) list some interesting ignition sources

/ Combustible Dusts /

In the most recent revision of the Globally Harmonized System of Classification and Labelling of Chemicals (GHS), they list some very interesting potential ignition sources for dust explosions; several I have never ever even considered being an ignition source.  Check these out…… Membership Required You must be a member to access this content.View Membership LevelsAlready...

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How fast is a 10 cm/sec flame front?

/ OSHA Compliance /

As we have discussed, the latest revisions of the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) has a new criterion for categorization of flammable gases.  The GHS now has sub-categories of CAT 1 Flammable Gases:  1A and 1B.  CAT 1B flammable gases have a fundamental burning velocity of less than 10 cm/s. …...

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Production facilities that recover natural gas liquids may have enforceable PSM-covered processes

/ Chemical Process Safety (PSM/RMP) /

Your inquiry relates to the enforcement of OSHA’s Process Safety Management (PSM) standard, 29 CFR 1910.119, to two hypothetical scenarios you provided that are related to upstream oil and gas production facilities. Background/Scenarios: In your letter, you describe the following scenarios involving natural gas processes that are in the production phase of upstream oil and…...

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OSHA’s 1926 PRCS standard and combing entry methods to avoid a permit-entry

/ Permit Required Confined Spaces /

One of the topics we have debated about 1910.146 is whether (c)(5) and (c)(7) entry methods could be used simultaneously on the same space.  I was a resounding “No” but since we could never get an official answer from OSHA, there were many in our profession who felt it was acceptable to use (c)(5) and…...

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We create a NON-Permit Required Confined Space

/ Permit Required Confined Spaces /

This is not meant to be controversial, but my experiences over the past 20 years tell me many will disagree. I stand by this article as the SAFE and COMPLIANT way to achieve a NON-Permit Required Confined Space. This article should have been written 20 years ago, as this topic has been misunderstood since OSHA…...

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Labeling Permit-Required Confined Spaces, Words Matter

/ Permit Required Confined Spaces /

Have you ever seen a Permit-Required Confined Space (PRCS) labeled using the term “Confined Space” instead of “Permit-Required Confined Space”?  Does it matter what we call them? … Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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EPA RMP citations @ gas processing facility (Flammables & $257K w/ $112K SEP)

/ PSM and RMP Citations/Analysis /

A gas distributor and its parent company have agreed to pay $257,000 to settle RMP violations discovered during inspections following a fatal 2013 explosion at a Texas facility.  On the morning of February 9, 2013, at the La Porte #1 facility, there were explosions and a fire. The Incident occurred in the Gravimetric Unit (“Unit”)…...

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Reflection on COVID19 and our Industrial Safety Model

/ Motivational Safety Materials /

Sitting here relaxing this Sunday afternoon, I am comforted in now knowing 100% why engineering controls rule over Admin Controls and PPE. As soon as President Trump and his team mentioned some alternative treatments this week for ridding the body of the virus, a lot of folks latched onto the ideas. Our society, which is…...

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OSHA citations for PRCS Fatality in Gasoline Storage Tank (Flashfire)

/ Permit Required Confined Spaces /

At 2:00 p.m. on September 20, 2019, an employee was inside of a 10,000-gallon fiberglass gasoline storage tank and was draining some brine water while cleaning the tank. The employee used a drill while inside the tank and ignited the gasoline vapors, exploding it and setting it on fire. The employee was caught in the…...

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