Safety Info Posts

Layers of Protection for Flammable Liquids

The protection provided by the 2021 IFC is to prevent flammable and combustible liquids from becoming ignited. This is accomplished by one or more of the following layers of protection:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Cell manufacturing, Acetone, a plastic office mat, and an office chair ends in serious injuries

I was asked to participate in a serious flash fire accident cause and origin investigation earlier this year.  The worker received severe injuries from the flash fire; they survived with life-altering injuries to their lower extremities.  The flash fire involved Acetone vapors from a manufacturing cell, an office chair, and a plastic chair mat.  Can…...

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Safety has to be a passion – not a job

Safety may be a skill that can be acquired over the years, but it is FIRST a PASSION to serve others that burns inside us. A PASSION dedicated to the men and women we are given the PRIVILEGE TO PROTECT. The men and women who do the dirty and dangerous work. Safety is ALL about…...

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Chemical Facility Anti-Terrorism Standards (CFATS) program EXPIRES

As of July 28, 2023, Congress has allowed the statutory authority for the Chemical Facility Anti-Terrorism Standards (CFATS) program (6 CFR Part 27) to expire. Therefore, CISA cannot enforce compliance with the CFATS regulations at this time. Due to this lapse in statutory authority, CISA cannot enforce compliance with the CFATS regulations. Access to the…...

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Prevent, Protect, and Mitigate through our Hierarchy of Controls (Mixer vs Shirt video)

So much to learn from this video.  OSH practices need to understand the concept of Layers of Protection:  Prevent, Protect, and Mitigate through our Hierarchy of Controls. GUARDING to PREVENT exposure to hazardous energy, NO LOOSE clothes around power transmission devices (even well-guarded devices) to PROTECT workers, E-Stop to MITIGATE the consequences when #1 and…...

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Thorough examination and testing of LEV (UK’s HSE)

Most of us have some form of “ventilation” used as an “engineering control” in our workplaces. This is sound advice from our friends “across the pond” in the UK… Note: although they are on a different continent and at a different latitude and longitude, airborne contaminants behave the same as in other countries on this…...

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Making the case that our Cl2 Emergency Response Kits need to be in a formal maintenance program

One common deficiency we encounter in our chlorine (Cl2) work is the management of these emergency response kits (e.g. A, B, and C Kits).  We find three common failures regardless of the type of Kit: Kit(s) is not inspected “routinely” Kit contents are not managed per their specific requirements (i.e.. hood gaskets) Personnel lack training…...

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Can a business ever live up to the mantra “Safety is #1”?

We hear and see this all the time.  There are variations to this mantra, but we all know what they mean.  So I ask, can a business ever live up to its mantra, “Safety is #1”? Some companies have softened their approach and will say, “The safety of our employees is our #1 priority”.  We…...

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The SMS Hazard Identification program

As I have stated, our Safety Management System (SMS) revolves around four (4) fundamental elements: 1) Hazard Identification 2) Analysing those identified hazards using recognized methodologies 3) Assessing the risk(s) those hazards pose to people, businesses, and the environment 4) Mitigating those risks down to a tolerable level using the Hierarchy of Controls With that…...

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What does SMS Leadership and Commitment look like?

It is well established that in organizations where a formal and structured SMS approach to managing safety failed, the #1 cause of the failure was the lack of leadership and commitment from the most senior management personnel.  Often these individuals lack experience working within a formal SMS structure and have never been taught or even…...

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Is a PSSR “necessary” for a Replacement in Kind (RIK)?

Notice I used the word “necessary” and not the word required.  In my experience, a PSSR saved my ass plenty of times when OSHA/EPA did NOT require it.  To my knowledge, OSHA (nor EPA) have defined the word “facilities” in the context they used it in 1910.119(i)(1)… (emphasis by me) 1910.119(i)(1) The employer shall perform…...

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EPA issues RMP & EPCRA citations @ food prcessing facility (NH3 & $650K)

The U.S. Environmental Protection Agency (EPA) and Justice Department have reached a settlement with a food processing company to resolve alleged violations of the Clean Air Act (CAA) and Emergency Planning and Community Right-to-Know Act (EPCRA) at the company’s food processing facility in North Kingstown, Rhode Island. The alleged violations pertain to chemical release prevention…...

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