As the debate continues about using “clamshells” as a lockout device, our behind-the-scenes discussions continue regarding OSHA’s use of the term “Substantial”. The discussion was so good I asked if I could summarize and post it to keep the discussions going. So once again, here is OSHA’s definition of a “Lockout device”: A device that…...
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Wearing a baseball cap while performing hot work may make you look cool, but just watch this video and we can see what OSHA was trying to prevent with… 1910.252(b)(3) Protective clothing General requirements Employees exposed to the hazards created by welding, cutting, or brazing operations shall be protected by personal protective equipment in accordance with the requirements of…...
Anyone who has worked with ASME/API pressure vessel codes knows the basic language used to describe Relief Valve (RV) discharge locations… “discharge to a safe location”. This requirement applies to ALL relief devices on all types of equipment and although OSHA does not have a specific standard on relief devices and their design, they will use…...
Way back in April 2016, the OSHRC published a decision that settled the argument about LOTO procedures for “specific equipment/machines” and what they must contain. This important decision helped settle a lot of scuttlebutt about how LOTO gets managed in “complex” situations. I like to explain to clients that LOTO in a chemical process is…...
A local client has requested another 40-hr Process Safety Management course and we have scheduled it for the first week of April 2018. The course will be at: Sugar Creek Packing Company 2600 N James H McGee Blvd Dayton, OH 45417 NOTE: this is the same location that held the “Safety for PSM/RMP Managers” course. Time: …...
On September 11, 2012, a Facility experienced a 284-pound release of anhydrous ammonia from its ammonia refrigeration system. The incident occurred when a worker attempted to defrost an ammonia chiller and opened the oil valve instead of the hot gas valve, causing ammonia to release into the environment. As a result of the release, an…...
We hear the phrase “safety culture” being tossed around in today’s management like it is some measurable object or goal. This, in its own right, shows the vast lack of understanding of what a safety culture is. My first boss, who I will always praise, was all about his employees. He wanted the very best…...
Just when we think we have seen the limits of human unsafe behaviors, we are reminded that humans are capable of reaching new heights of UNSAFE behaviors when they work as a team!… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
As the tragic trenching accidents continue to stack up, this week’s photo shows us that merely providing a protective device(s) is ONLY HALF the challenge. As we can see, Trenching also creates fall hazards as well…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
Last year I broke down the pressure and leak test requirements found in ASME B31.5 for those of you in the Ammonia Refrigeration industry, and at the time, I promised I would do the same for those of you that use ASME B31.3 in all the other process industries. And as I got busy with…...
To follow up on the post from yesterday regarding the use of these “lockout devices”, I was reminded by many of you in the same camp as me, that these devices are also highly questionable when we look at their ability to meet the “substantial“ requirement. These safety pros all agreed that the use of…...
