As is evident by several Permit-Required Confined Space incidents over the years, workers MUST FULLY understand the limitations of the respirators they are using. This latest incident involved a worker who was vacuuming, and the nozzle became stuck inside the tank. To free the nozzle, the worker—wearing a respirator with organic filters used explicitly for…...
Knowing the limitations of the respirator is CRITICAL Read More »
This week, I conducted a 24-hr HAZMAT Tech course for a client. The facility had purchased some new SCBA cylinders, and we noticed an odd difference between two of the cylinders. One cylinder was manufactured in 2021, and one was manufactured in early 2022, just six months apart. As I was covering the requirements for…...
Emergency Use Only SCBA and 90% Full Read More »
This is an interesting “press release” from OSHA. Although OSHA has a “policy” not to use audits and inspections performed within the facility to issue citations against, when the employer does NOT address the hazards identified in the inspections and audits, OSHA can take issue with this failure to abate. This is what seems to…...
Employer failed to address 3rd party OSH audit findings ($348K) Read More »
Unfortunately, this economic image reminds me of some “safety programs” I have come across in my travels… The “program” looks great, sitting on the shelf in the fancy, shiny binder. But once we open the binder/package, we find a lot of “fluff” (i.e., air)! Let’s be serious… Safety is not a marketing or PR exercise…...
Is safety like bags of chips… half full of air? Read More »
Why is it that safety metrics always get such a bad wrap? We hear the voices from the back of the room… “what gets measured, gets manipulated,” so the outcry is that somehow measuring safety (other than the regulatory lagging indicators) is a waste of time and misleading. The funny thing is I never hear…...
Make safety data as coveted as financial data Read More »
Immediate Action Required Impacted Dates: October 3, 2023 – December 4 ,2023 3M™ Scott™ Cylinder and Valve Assemblies are safe to use once the instructions in this notice are carried out. 3M Scott have been made aware of a small number of cylinder valves that experienced noticeable rates of leakage upon initial inspection when the…...
User Safety Notice SN122223 – 3M™ Scott™ Cylinder and Valve Assemblies Read More »
One of the most recognizable safety devices in the world is a Fire Extinguisher, yet so many know so little about these devices. Let me be upfront with everyone; this article is for those safety pros working with a management team that WANTS to OWN the Safety Process/SMS. The actions I will offer in this…...
Using a common safety device to build the bridge for “management’s ownership” of safety Read More »
FRA is amending its regulations related to occupational noise exposure in three (3) ways. Special NOTE: although I agree with this new requirement, it will be virtually impossible for the railroads to comply by March 2024. There are NOT enough EEBAs in inventory to supply the Class 1s. Then there is the written program and…...
FRA requiring Emergency Escape Breathing Apparatus (EEBA) on some locomotives Read More »
I see far more damage to atmospheric storage tanks from vacuums than I do from over-pressure events. In almost every case, the tank had undergone a “change” that created the conditions for a vacuum to occur. And once we have a pressure differential with a lower pressure inside the tank than the atmospheric outside the…...
The power of a vacuum (Flammable Liquid Storage Tanks) Read More »
This image from a UK HSE publication may be the best image I have seen on “process safety” and Basic Process Controls Systems (BPCS). It shows how we PREVENT “overfill” events, also known as a Loss of Primary Containment (LOPC) event in atmospheric storage tanks/vessels. The entire publication is a MUST-read for those who store…...
Basic Process Controls Systems (BPCS) for flammable liquids storage tank(s) Read More »
A common question we get regarding flammable liquids is: Do we have to ground and bond non-conductive containers smaller than 5 gallons? The proper question should be… what do we need to do to SAFELY transfer flammable liquids into non-conductive containers that are 5 gallons and smaller? The British Columbian Worker’s Compensation Board…...
The battle continues, this time outside process safety! I get these arguments routinely when people inquire if they can use their HHC/EHS as the media for pressure and leak testing. I can only assume that PHMSA is getting pushback by requiring water or other similar viscosity liquid to be used as the test medium. When…...
PHMSA asking for feedback on “requiring water be the fluid for Hydro testing containers” Read More »
