SPECIAL NOTE: This appears to be the first case where OSHA has applied it’s new Instance-by-Instance Penalty for Willful Citations.  This case involved a leg amupation while working inside a sile with the paddle conveyor still running.  OSHA issued three (3) Willfuls using 1910.28(b)(6)(i) for each citation and all three (3) were willfuls. An grain cooperative’s failure to ensure...

There is a common phrase in Human Factors Engineering… “Error Trap.” This is the image we will put next to this phrase in my new book… (i.e., an actual real-life “error trap” door). Scenario: Your singing your favorite song in the shower. The spouse needs to go down to the basement and start a load of clothes in the washer. They open the door BUT DO NOT CLOSE IT,...

When writing SWPs/SOPs be sure how you phrase things. KNOW your audience. An elementary teacher got what she asked for when she simply asked the class to draw a clock showing the time as 10 minutes past 11. This exercise is called the Clock Drawing Test for Cognition. Usually reserved for the elderly or someone who has suffered a brain injury, the test can also indicate some learning disabilities in...

This case is significant as EPA used the International Fire Code as their basis for several General Duty Clause findings.  They also used NFPA standards in their inspection. Respondent owns and operates a facility that manufactures consumer and industrial products in liquid form and for pressurized containers that use aerosol propellants. Respondent’s manufacturing process uses and stores flammable...

A recent FaceBook post by the South Dakota Highway Patrol is getting a lot of attention. The pics are alarming, to say the least. But some of the comments are an indication of where safety stands in the United States culture of safety.  When people decry government intervention as “crossing a line,”… “that truck driver is just trying to make a living, maybe if the government...

Over the past several years, I have focused on my SMS/HF postings rather than the traditional technical postings. Being a safety pro means we wear many hats. I break these down into just two (2) main categories: 1) Technical and 2) Management Systems, including the soft skills we need to possess. Those who have followed me over the years know I love the technical side. But those who have worked with...

The Institute of Nuclear Power Operations (INPO) manages the Significant Event and Information Network for its member utilities both within and outside the United States. In 1985 they issued an analysis of 180 significant event reports received in 1983- 84 (INPO 1985).  A total of 387 root causes were identified. These were assigned to five (5) main categories: … HomeRead More &raqu...

Human error can be divided into either intentional or unintentional actions. INTENTIONAL actions—those actions that involve conscious choices. These actions are primarily due to judgment or motivational processes. UNINTENTIONAL actions—those in which the right intention or plan is incorrectly carried out or where there is a failure to carry out an action. These actions typically occur due to attention...

Before disciplining a worker for an “error” or “mistake” that led to undesired consequences, we need to ask ourselves one simple question… How often have we written 2022 when signing checks and documents this year? It is February 15th, 46 days into the new year, yet I just had to correct a document that I signed and dated 2022. Should I be disciplined for this “slip”?...

In OSHA’s LOTO standard, they incorporated a requirement that required businesses to have forethought about the means used to isolate energy.  Specifically, the standard requires: 1910.147(c)(2)(iii) After January 2, 1990, whenever replacement or major repair, renovation or modification of a machine or equipment is performed, and whenever new machines or equipment are installed, energy...

Since the train derailment in Palestine, OH, on February 3, many have heard the statistic… More than 99.98% of rail hazmat shipments reach their destination without a release caused by a train accident. Source: https://www.aar.org/wp-content/uploads/2020/10/AAR-Hazmat-Fact-Sheet.pdf That statistic may very well be accurate; however, without understanding the definitions used, there could be some...

Last month I wrote a few posts about how a compliance manual made up of dozens of individual safety programs written for OSHA compliance needs is not a safety management system (SMS).  That post got a lot of friends to encourage me to expand on that position and explain what I meant.  So using one of my favorite OSHA standards, I want to demonstrate how Lockout/Tagout (LOTO) can indeed be...