Safety Info Posts

Why are the pressure vessels in my PSM/RMP covered processes managed differently than those “every day” type pressure vessels?

Recently I had a client who made alterations to a pressure vessel (PV) in an ammonia refrigeration process that required the PV to be re-certified. The state where this PV resides is a “coded state”, meaning they have adopted ASME Code for the PVs within the state. So, the contractor making the alterations had scheduled…...

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Is API 570 your Piping Inspection/Repair RAGAGEP… Repair Requirements are now crystal clear

If API 570 is your facility’s piping inspection/repair RAGAGEP, the battle over “repair requirements” just got easier!  A very popular question in PSM/RMP circles has become… “Do we have to make repairs in the same manner as we did the initial install of the pipe?” In other words, what is being asked is… “Can we bypass…...

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OSHA’s position on flammable liquids (.106) and PSM (.119) with regard to PD pumps in a process

Scenario 1: The first scenario you described has the following attributes: Your firm is engaged in the design and construction of a manufacturing (processing) facility which includes OSHA Category 2, 3, and 4 flammable liquids as raw materials and processing intermediates. The Food and Drug Administration and countries in Europe, the Middle East, and Africa…...

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Is your Pulmonary Function Testing (PFT) being performed by “qualified personnel”?

Another aspect of a “respiratory protection program” often times will include a PFT as part of the “medical evaluation”.  For the most part, these PFTs are done by the location where the PLHP resides and most of the time they are done by “trained” personnel – but how many of us actually audit the service provider…...

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What does OSHA now require for annual submittal of Injury and Illness data?

I have received a number of e-mails, text, and phone calls concerning OSHA’s change in their Electronic Filing of Injury and Illness data.   Bottom Line… 300A Annual Summary Data is all that is required to be submitted for those establishments that have 250 or more employees.  TIP: “employees” are that personnel on site that if they…...

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Nitrogen Dewars @ Spa and the OH Fire Code

Fire Codes mean something… at least in our world of occupational safety and health.  As I was entering a restaurant for dinner, I am checking out my environment and what do I see but two (2) dewars of Nitrogen in some kind of “float spa”.  This was in a “strip mall” type setting so of course,…...

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Catastrophic failures of SCBA cylinders

On July 11, 1996 a member of the Roxbury Township, Morris County, Fire Department, Firefighter Paul Label, age 29, was in the process of recharging an aluminum 2216 psi SCBA cylinder from the department’s cascade system at about 2038 hours, when it failed catastrophically resulting in serious injuries to Mr. Label. On October 8, 1996…...

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OSHRC LOTO decision on “unexpected start-up”

WOW… just WOW!  I feel like I am in the twilight zone after reading this decision.  I am not a big fan of government shutdowns, but right now, I wish the OSHRC would get shut down.  It is rare, but it does happen when I take serious issues with decisions of the OSHRC, and this…...

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SAFTENG’s 2019 Respiratory Protection Program Administrator Course Manual

I just completed my first 2019 Respiratory Protection Program Administrator Course, and again it was a blast!  This has become one of my favorite courses to teach for many reasons, but primarily, it is the learning curve of so many students.  Most cannot answer 25% of the questions on the pre-test, and in just 1.5 days,…...

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The four (4) things one must know before selecting an APR

The selection of a respirator can be confusing, but if we keep just four (4) things in mind we can at least determine if we can use an Air-Purifying Respirator (APR).  These four things are:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Respirator Selection Process (WA-OSHA)

Step 1: If your only respirator use is for escape, skip to Step 8 to select the appropriate respirator.   Step 2: If the respiratory hazard is a biological aerosol, such as TB (tuberculosis), anthrax, psittacosis (parrot fever), or hanta virus, select a respirator appropriate for non-emergency activities recognized to present a health risk to…...

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