Safety Info Posts

Does 1910.146 allow (c)(5) AND (c)(7) to be used on the same PRCS at the same time? (Part 2)

A couple of weeks I posed this question, and I figured there is NOT a consensus among the safety community (including OSHA) as to whether (c)(5) AND (c)(7) can be used on the same PRCS at the same time.  My position is NO, they can not be; but I am only one voice in the debate,…...

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Managing your HFO-1234yf BLEVE risk (Part 6)

A few months ago I wrote about this new refrigerant as having the catastrophic risk of a BLEVE event. Now I wish to offer some guidance on how a business utilizing this refrigerant can reduce the likelihood of this type of event.  First, there are NO engineering standards that guide a manufacturer of an ASME…...

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2016 Video of the Week #6 (Skid Steer Loading Accident)

This is what happens when we load heavy equipment like fools.  Too many videos of “succesful” (although foolish) attempts at loading this type of equipment into the back of trucks UNSAFELY and now it seems everyone thinks they can do it.  Here is a failure mode that one would think would cross the worker(s) minds…...

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EPA RMP citations @ Nitrogen plant (NH3, CL2, SO2, & $26K w/ SEP $98K)

Respondent has five RMProgram covered processes. The letdown area process, the urea process, and the high pressure solutions process store or otherwise use ammonia in an amount exceeding its applicable threshold of 10,000 pounds; the chlorine addition process stores or otherwise uses chlorine in an amount exceeding its applicable threshold of 2,500 pounds; and the…...

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E-Stop buttons MUST be “red in color”

We dont see this citation very often, but it is a standard and it is one that we use often… 1910.144(a)(1)(iii) Stop. Emergency stop bars on hazardous machines such as rubber mills, wire blocks, flat work ironers, etc., shall be red. Stop buttons or electrical switches which letters or other markings appear, used for emergency stopping…...

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Does 1910.146 allow (c)(5) AND (c)(7) to be used on the same PRCS at the same time?

As we know, 1910.146 gives employers three (3) methods to enter Permit-Required Confined Spaces: 1) Full permitted entry following (d)-(k), 2) alternative entry methods prescribed in (c)(5), and 3) reclassification of the PRCS to a non-permit space by following (c)(7). However, in the past year or so, we have come across another method… using BOTH…...

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Workers hurt when pressurized fluid escapes (LOTO Incident @ Mine)

This incident is a PERFECT example of what can happen when STORED ENERGY is overlooked.  For energy sources like hydraulics and pneumatic (e.g., gases), merely closing a valve and locking it closed or locking out a pump is NOT full energy control.  Procedures MUST include the means to dissipate the stored energy to the Zero…...

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EPA RMP General Duty Clause citations @ chemical packaging facility (Sodium Chlorite chemical reaction & $37,5K)

Respondent is a corporation authorized to do business in the State of Texas. Respondent owns and operates a chemical building, manufacturing, and packaging facility. Respondent receives bulk raw chemicals, including liquid sodium chlorite, delivered in tanker, railcar, and packaged containers. Respondent uses these raw ingredients to produce finished products. Liquid sodium chlorite is an extremely…...

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EPA RMP, CERCLA, EPCRA citations @ fertilizer distributor after 600 pound NH3 release (NH3 & $34K, w/ $15K SEP)

Respondent is a fertilizer distributor engaged in the business of selling anhydrous ammonia to farmers as fertilizer. Anhydrous ammonia is classified as a physical or health hazard, and a simple asphyxiant and therefore is an “extremely hazardous substance” according to Section 302(a)(2) of EPCRA. The Respondent stores more than 10,000 lbs. of anhydrous ammonia at…...

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