A former client had an amputation accident, and an OSHA inspection followed, with several citations following that. We were hired to help the company digest all that OSHA found wrong, and there was plenty that OSHA found, but there was even more that OSHA did not see or address with its inspection or citations. The…...
When meeting with executive teams, I like to conduct an exercise to gauge the leadership team’s level of knowledge and direct involvement in the safety and health of their employees. Before getting deep into the organization’s specific barriers/controls/safeguards regarding their top 3 risks (which the team picks), I ask the team to take 10 minutes…...
How well does management know the “barriers/controls/safeguards”? Read More »
We see these silly stickers occasionally in our work with clients. Although they are not official company positions, I am curious as to why they aren’t removed from company machinery and equipment. Could this be because management/supervisors believe this to be an accurate statement/belief? But let’s talk about the message these silly stickers really convey…...
The seven C’s of being all we can be as safety professionals. Compassionate Confident Collaborative Contemplative Civil Curious, and Courageous Let us remember WHY we became safety professionals AND, more importantly, putting those we have the privilege to protect # 1 in our efforts. Source: 7 C’s of Compassionate Leaders (Forbes)… Membership...
I have grown up in safety and emergency response and found that the tools used in both aspects can cross over to the other. For example, I use the National Incident Management System (NIMS) Incident Command on accident investigations to bring structure to the team. In that IC we have a “span of control” of…...
Does staffing impact the culture of safety? Read More »
This is an unusual case in that it involved a 20-pound release of NH3 during a “line break” on a refrigeration system. There was only a single citation and it came at a price of $38,500. The employee was injured. I have been unable to locate an OSHA investigation regarding this incident, which occurred in…...
EPA issues RMP citations @ cheese manufacturing plant (NH3, Line Break Accident, & $38K) Read More »
I have been involved with emergency response for over 30 years. During those years, I trained thousands of municipal and private responders, specializing in traditional Hazardous Materials Responses. During all those years, when I received continuing training from the likes of Texas A&M, LSU, NFA, and SERTC, these advanced courses only validated my first HAZWOPER…...
A DECON practice challenge Read More »
Not all “simple asphyxiants” are created equal; thus, not all make for good purging or blanketing. Would you believe me if I told you that one very common simple asphyxiant gas should NEVER be used for purging or blanketing flammable atmospheres? Many folks view Nitrogen (N2) and Carbon Dioxide (CO2) as very similar. This is…...
Inerting a flammable atm is more of a science than art Read More »
Yes. OSHA’s standards at 29 CFR § 1910.212 and 29 CFR § 1910.219 apply to the safeguarding of machines and mechanical power-transmission equipment and require guarding to protect the operator and other employees in the area from hazards such as those created by ingoing nip points, rotating parts, flying chips, and sparks. In regard to…...
I am a proponent of accountability in safety; however, I also believe that accountability is necessary at all levels of the organization. We tend to be very quick in identifying the ACTIVE failures by those who made the error, mistake, or violation, and a negative consequence was the result (vs. all those times, the outcome…...
Something to think about when preparing to issue discipline to those closest to the risk Read More »
Some of the more eye-opening revisions: Outlining STOP-WORK procedures in Program 3 employee participation plans A justification in the risk management plan is required when: hazard evaluation recommendations are NOT adopted facility-siting hazard recommendations are NOT adopted Safer Technology Alternatives Analysis (STAA) recommendations are NOT adopted third-party compliance audit recommendations are NOT adopted A formal…...
DOT/PHMSA have compiled the most important changes from ERG2020 to ERG2024, organized by the color of the corresponding section in the guidebook White Yellow/Blue Orange, and Green In addition to the changes listed below, all sections have undergone minor editorial changes for accuracy and consistency. In this edition, DOT/PHMSA has added QR codes to the back…...
2024 DOT ERG is coming! Read More »
