A client has allowed me to share work I did several years ago when OSHA’s GHS threw a wrench into the flammable liquids world! There was so much confusion between Class and Category of flammable liquids, and during an engineering review, it was discovered that the engineering group had made a conversion error when going […]
When most ordinary people hear the term “Hazardous Location” many conjure images of a dangerous location associated with typical hazards; however, when a safety engineer or engineer from the process industries hear the phrase we immediately elvate our antenna and sit up and pay close attention to what is being said. But for those outside
In 2014, the Occupational Safety and Health Review Commission (OSHRC) issued a judgment on an OSHA case, and in the case, they made it clear that “magnitude” matters in lockout/tagout (LOTO). But for some reason, this piece of data is absent from many machine-specific LOTO procedures and OSHA always takes issue with this oversight. So
In 2013, we discussed the OSHA and NFPA requirements for “identifying fire extinguishers” in Fire Extinguishers… Did you know they have to be identified? In that article, we touched on the OSHA and NFPA requirements for how fire extinguisher LOCATION(s) (not the actual fire extinguishers) are to be identified. But how many of us see
What do you get when you have no “qualified/competent” person on site who fully understands the implementation of a Confined Space program AND OSHA’s eTool Industry page is being read literally by the unqualified worker? The answer: SERIOUS PRCS PROBLEMS! I had a smile on my face the entire time I was thinking about how
With year 2020 already claiming 7 lives inside PRCSs within the USA, I have to ask the question: Has OSHA’s Permit-Required Confined Space standard meet its goal? In OSHA’s Preamble for 1910.146, published in 1993, OSHA stated: OSHA has determined that permit spaces pose significant risks to employees (62 fatalities and 12,643 injuries and illnesses annually) and estimates that compliance
Why is this article posted in the Permit-Required Confined Space section of the website? Because there seem to be a large number of safety professionals that are under the impression that ANY occupational hazard can turn a confined space into a Permit-Required Confined Space. Noise is a recognized occupational hazard – I think we can
The Joint TDG-GHS informal working group (IWG) dealing with the categorization of flammable gases was organized in Brussels from 9 to 11 March 2015 by the Belgian and the Japanese delegations to the TDG and GHS sub-committees. The participants (physically/by phone) list can be found in Annex 1of this report. The purpose of this IWG
The requirement for pressure and leak testing on PSV vent piping depends entirely on whether the piping is classified as Boiler External Piping (BEP) or Non-Boiler External Piping (NBEP). If the vent line is part of the BEP (directly attached to the boiler safety valves under the jurisdiction of ASME Section I), the testing requirements
So many learnings! This happened in the Year 2000. Listen to the radio traffic where the IC is asking for a “headcount”!!!!
I can still remember the day I was told: “the pipe failed its thickness testing – but don’t worry we are going to use a pipe clamp so we can keep using it”. I had just attended my API 570 and 510 courses to learn all about process equipment inspection protocols. Not once did I
Canada has an interesting requirement for their NH3 refrigeration plants that operate within structures where the general public could be exposed to the NH3. Since the promulgation of OSHA’s PSM standards in 1992, OSHA has shied away from even mentioning “staffing” for a covered process. In the USA, we have plants that run 24/7/365 without
