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Contractor Safety - Evaluation Tip
Recently a former client was cited for hiring a contractor who was not qualified for the work they were hired to perform.  Also, do not lose sight of the fact that this contractor was NOT cited for any OSHA violation as they did not violate their responsibilities under 1910.119(h)(3), although some may argue they violated (h)(3)(v) in principle.  What we found out was that the contractor...
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Don't say it is "locked out" when the isolation devices on the energy soures are NOT locked in their safe positions
At 8:00 a.m. on March 15, 2021, Employee #1 removed, cleaned, prepared the surface and replaced the blow-in door gasket seals on the USS McFaul. The door was TAGGED OUT in the OPEN position; however, in this position, the pneumatic pressure and electric power could NOT be secured in its SAFE POSITION. While performing the work, the door closed on the employee, crushing her. She died from the resulting...
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Stored energy fatality (Air compressor/dryer)
At 1:15 p.m. on 11/3/2020, a worker employed by an HVAC company, was working at a customer’s commercial facility. He was in the process of removing a coupler and blind from the intake header of an air dryer. The employee did NOT first relieve the air pressure from the header. … HomeRead More »
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Stored energy fatality (NG compressor)
At 9:45 a.m. on December 11, 2020, an employee was preparing to do maintenance on a natural gas (NG) compressor. The compressor was not prepared for maintenance correctly (e.g., not LOTO’ed properly), pressure built up, and an engine cap struck the employee on the head. … HomeRead More »
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Hazardous atmopsheres inside PRCS can kill workers outside of the space
We see it happen every once in a while, a worker has their face in the opening of the space.  They are exposed to the hazardous atmosphere within the space as the only air flow out of the space (which is at higher pressure) is right past their breathing zone.  They are exposed and unfortunately, sometimes these exposures are fatal.  Take this 2018 OSHA Case, at 5:00 a.m. on September...
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OSHA issues PSM citations @ refinery (Flammables & $259K)
Oil and vapor releases into the air and fiery flares at a refinery in February and May led to an investigation that found the operator failed to meet federal workplace chemical safety standards and endangered workers.  OSHA cited the refinery for 20 violations of the Process Safety Management standard with $259,407 in proposed penalties. OSHA determined that the Refinery did not: … HomeRead...
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OSHA publishes its Heat Initiative: Inspection Guidance
In a memorandum to Regional Administrators, OSHA establishes an enforcement initiative to prevent and protect employees from serious heat-related illnesses and deaths while working in hazardous hot indoor or outdoor environments.  It expands on the agency’s ongoing heat-related illness prevention campaign by setting forth the enforcement component and reiterating its compliance assistance and...
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EPA issues RMP/EPCRA ENFORCEMENT ALERT: "Risks of Improper Storage of Hazardous Chemicals at Chemical Warehouses and Distribution Facilities"
Some chemical warehouses and distribution facilities may be failing to properly manage hazardous chemicals as required by federal law. In the past several years, the EPA has visited numerous chemical warehouses and distribution facilities (i.e., companies that process, formulate, blend, re–package, store, transport, and market chemical products) to determine compliance with the Clean Air Act...
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EPA is adding natural gas processing (NGP) facilities to EPCRA/TRI
EPA is adding natural gas processing (NGP) facilities (also known as natural gas liquid extraction facilities) to the scope of the industrial sectors covered by the reporting requirements of the Emergency Planning and Community Right-to-Know Act (EPCRA), commonly known as the Toxics Release Inventory (TRI), and the Pollution Prevention Act (PPA).  … HomeRead More »
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Group E (Metal Dusts) only have Div 1 locations (NFPA 499)
An old dog is never too old to learn something new. NOTE: This clarification was made in the 2021 edition of NFPA 499. In NFPA 499, the definition of a Class II, Div 1 HAZLOC is as follows: (emphasis by me) … HomeRead More »
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Will OSHA's new "Emergency Response" standard establish Engine Company staffing levels?
As discussed, OSHA is making significant revisions to its Fire Brigade standard.  And in the DRAFT version, OSHA establishes a minimum staffing level for working/entering an IDLH atmosphere.  Many of you who are part of or manage the fire brigade may recall that OSHA has made room for “judgment” regarding staffing available and performing life-saving operations.  In fact,...
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OSHA's new "Emergency Response" standard and responder medical/fitness requirements
This provision of the draft standard would, based on the type and level of service(s) established by the Emergency Service Organizations (ESO), require the ESO to establish minimum medical requirements based on the tiers of responder duties, tasks, and responsibilities. A qualified healthcare professional would perform the medical evaluation of the responders. The medical evaluation would include a...
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