This case is before the Commission on remand from the United States Court of Appeals for the Second Circuit.  Administrative Law Judge Keith E. Bell affirmed a citation issued by the Occupational Safety and Health Administration, alleging that pallets of merchandise kept on racks at a distribution center were “stored in tiers” but not “blocked . . . so that they [were] stable and secure against...

If your management is only reactive to an accident, it is probably a built-in response because all the safety metrics are reactionary as well. When the sole safety metric is an injury rate, events that do not impact that injury rate do not garner a management response simply because they did not move the needle by which management is measured in safety.

This week OSHA published the Compliance Directive for Region IV’s Regional Emphasis Program (REP) for Safety Hazards in Auto Parts Industry – NAICS 3363XX (Motor Vehicle Parts Manufacturing).   Data from the Bureau of Labor Statistics (BLS) shows that in 2021 the auto parts supplier industry had higher injury and illness rates – 3.3 per 100 full-time workers – than private industry...

A worker died of acute hydrogen sulfide (H2S) poisoning while responding to an alarming water pump involved in the process of extracting crude oil and natural gas. The worker was alone in the pump house, attempting to close process valves to isolate the pump. The pump unexpectedly energized either before the worker’s arrival or during his work, releasing water containing H2S gas into the pump house. ...

The Respondent operates a frozen poultry storage facility. The Facility is located within several hundred feet of residences.  Respondent uses 15,900 pounds of anhydrous ammonia in a refrigeration “process,” as defined by 40 C.F.R. § 68.3, in a system of pipes and vessels at the facility (the “Process”).    On June 6, 2019, EPA inspectors visited the facility...

The Emergency Planning and Community Right-to-Know Act (EPCRA) establishes requirements for federal, state, and local governments, Indian tribes, and industry regarding emergency planning and reporting on hazardous and toxic chemicals. Individual facilities are required to conduct emergency planning with state and local emergency planning committees, report accidental releases to the proper authorities,...

When a manufacturer or importer ships defective/rejected Li-ion batteries for disposal or recycling, they are required to provide an HCS-compliant SDS to downstream employers. An HCS-compliant label would not be required for a product that is regulated under the CPSC.7 For example, consumer products that are generally regulated by the CPSC include button cells (e.g., watch batteries), small batteries...

This [Portable] Rechargeable Battery Association (PRBA) inquiry includes a number of scenarios and questions raised by its members related to the article determination, hazard classification, consumer product exemptions, and labeling requirements The PRBA scenarios and questions have been paraphrased, followed by our responses. In addition, Attachment 1 to this letter provides several scenarios to...

Once again, I can not stress how valuable FM Global can be to your safety efforts.  Their Loss Prevention Data Sheets are FREE and some of the best guidance we can find.  Our profession is always complaining about spending money on ANSI, ASME, NFPA, etc. codes and standards. Yet, these Loss Prevention Data Sheets are FREE, so there is no excuse for not utilizing these documents to improve...

For most senior safety professionals, we have arrived at a place in our careers where we can understand the significance of what Dr. Reason said in 1997.  Although most would agree, we started our careers in a very different place when it comes to how we derived the root causes of accidents throughout our careers.  But when Dr. Reason stated this in 1997, it was not well received; especially...

The significance (or severity) of an event depends upon the consequences suffered and not on the error that initiates it. The error that triggers a serious accident … and the error that is one of hundreds with no consequences… can be the same error.   Human Error, James Reason, Department of Psychology University of Manchester, 1990

Now keep in mind this is a child in the video.  But that does not mean adults would not do something similar after watching a co-worker successfully pull it off!  After all, MOST, if not all, unsafe acts are learned actions from co-workers.  So watch this short video, as painful as it may be to some, and answer the question, is this an Error, Mistake, or Violation using Dr. James Reason’s...