The state of MA has modified it’s State HAZMAT code, formerly called 527 CMR 33.00: Hazardous Material Process or Processing. The process safety code, now found in the State Fire Cide, Chapter 60, Hazardous Materials, has added a “performance alternative”, as well as providing more specifics and updating definitions. Here is what’s new: NOTE: Still…...
OSHA has two (2) significant LOIs, both aligning, and their HAZWOPER CPL that do a really good job of explaining how one crosses over from PSM SOP actions to actions that would fall under the definition of an “emergency response”, thus moving compliance from 1910.119 to 1910.120. I have presented both of these LOIs and…...
I have to admit that this transition from the old HAZCOM to this Globally Harmonized Hazcom Standard has been a bumpy ride over the past 4-5 years. I have had to correct postings a couple of times with some help from my friends at OSHA and NFPA. But there is one thing that I…...
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Every time I watch this video I think back to my days as a lifeguard and realizing that was my very first form of TRAINING. I was a Boy Scout and was about 14-15 years old and already knew I wanted to be a rescuer and just fell in love with the intensity of my…...
What obligations does the host employer have when they hire a contractor to work within one of their Permit-Required Confined Spaces (PRCS)? The answer seems to be all over the map, depending on the industry where the space is located, the size of the company, the company’s written program, etc. This article is intended to…...
This is a very good case on machine guarding (1910.212) application. Employees routinely reached under a set of doors that were interlocked to clear a jam. One day and employee reached too far and lost his finger tip. OSHA cited 1910.212(a)(3)(ii) and the commission upheld it. The reason why this case is so solid for…...
November 10, 2016 MEMORANDUM FOR: REGIONAL ADMINISTRATORS STATE DESIGNEES THROUGH: DOROTHY DOUGHERTY …...
Today the U.S. Chemical Safety Board released their report into a 2015 refinery explosion and in their report they reference one of my favorite documents of all time from the U.K.’s Health and Safety Executive (HSE), The safe isolation of plant and equipment. Another EXCELLENT diagram we can incorporate into our energy isolation plans for Line Break/Equipment Opening and…...
On December 19, 2016, OSHA issued a final rule titled, “Clarification of Employer’s Continuing Obligation to Make and Maintain an Accurate Record of Each Recordable Injury and Illness.” See 81 FR 91792. The final rule, which became effective on January 18, 2017, resulted in various amendments to OSHA’s recordkeeping regulations clarifying that the duty to make…...
This week I received this e-mail from a long-time SAFTENG member. Mike is a safety pro in the construction industry and he is trying to comply with OSHA’s new Confined Spaces in Construction, specifically, Mike has learned the hard-way that “rescue plans” can not be the proverbial “911 Rescue Plan”. Here is Mike in his…...
Respondent’s facility is a frozen food processing facility which primarily produces frozen dinners and entrees. As part of this process, Respondent uses ammonia in its plate freezers. On May 2, 2016 at approximately 2:35 p.m., a change in position of the stacking trays or plates located in Plate Freezer 1-6 caused the routine horizontality a1mm to…...
