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Hazard ID is fundamental to any SMS and an ALJ who gets it

Sometimes a lawyer or set of lawyers can surprise us… This is a quote from a recent OSHRC ALJ decision, regarding the employer’s responsibility to conduct inspections of the workplace to identify and correct hazards: “As an employer, Respondent is obligated to provide safe working conditions and ensure safe work practices. Implicit in that obligation […]

RESPECT the Cl2

At approximately 9:45 p.m. on November 4, 2003, a maintenance employee went to the chlorine house to turn on the chlorination system. The chlorine house measured 3 feet, 10-inches wide by 5 feet, 10-inches long and was approximately 10-feet high. The water lines ran through a hole in the block wall. The hole in the

Example of “Short-Threading”

One of the things I look for in my PSSR walk downs is “short-threading”. I was raised with the old pipe-fitters rule of “three threads showing”; however, ASME now accepts “full engagement” as bolt flush with nut. Some companies will have a QA/QC requirement of 1-thread showing. So I have to accept the ASME definition

Hazards of evacuating NH3 from the process

On February 7, 2017, an employee, 50, was making preparations to replace the relief valve of a 1,000-gallon ammonia (NH3) tank. The incident investigation reported that the tank was empty of liquid NH3. However, it contained approximately 80 psi of vapor pressure. The employee set up a 30-gallon drum that contained water and affixed it

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