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Another example of a worker on the incoming shift killing a co-worker on the out-going shift all because the lack of LOTO
This happens more often than most think: At 6:30 a.m. on December 7, 2022, an employee was removing wood bark from a de-barker machine at the CHANGE OF NIGHT SHIFT WHEN A DAY SHIFT COWORKER STARTED THE DE- BARKER. The employee was crushed and killed due to internal injuries. Had the worker performing the “cleaning” task specifically called out as one requiring LOTO, he/she would still be...
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EPA is enforcing the amended ER Planning and Response requirements (40 C.F.R. § 68.93(a) & (c)
EPA recently issued two citations to a juice processing facility for failing to comply with the amended requirements in 40 C.F.R. § 68.93(a) & (c).  On March 21, 2022, an incident at the ammonia refrigeration facility resulted in an accidental release (the “Incident “). Pursuant to Section 114 of the CAA, 42 U.S.C. § 7414, the EPA requested, and Respondent provided, documentation...
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EPA issues RMP citations @ refinery (Flammables and Toxics & $134K)
Respondent has a refining process meeting the definition of “process”, as defined by 40 C.F.R. § 68.3. Methane, ethane, propane, pentane, propylene, hydrogen, butane, hydrogen sulfide, and ammonia are each a “regulated substance” pursuant to 40 C.F.R. § 68.3. The threshold quantity for methane, ethane, propane, pentane, propylene, hydrogen, butane, hydrogen · sulfide, and ammonia...
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Safety Thought of the Week... Organizational silence: the best enemy of safety
Several organizational characteristics can feed organizational silence: Managerial illusions: managers can believe that the situation is under control simply because of the number of procedures. They can also believe that failure to follow a procedure is the only possible mechanism that can produce accidents. This discourages feedback about situations where procedures are difficult, time-consuming,...
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Defending H. W. Heinrich's work... industrial management is well equipped to solve its employee-safety problems
It is commonly admitted that the great majority of industrial accidents are caused directly by specific unsafe acts of persons or exposure to specific mechanical or physical hazards. It is agreed that these causes and the accidents that they create interfere seriously with the quality, volume, and cost of production and are of a preventable nature. There is general agreement, also, that successful...
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SIF can be transformational when it is the right time to make the move
The client this week had such an eye-opening experience with the risk assessment yesterday; they were all early this morning and had written out their homework assignment for the night! We took their loading docks and did the OSH version of LOPA called a Hierarchal Analysis around workers being crushed by a trailer at the docks and forklifts falling off a dock or out of a truck as it pulls away. We...
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Why is safety so difficult to manage?
As safety pros return to work this week from the annual ASSP conference last week, their excitement and enthusiasm will either blossom or bottom out.  So many new techniques are being pushed in the safety arena these days, and many safety pros and management personnel are grasping for whatever it takes to turn their safety performance around.  So with all these ground-breaking techniques...
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Modified Wrench BSEE
Adaptation and Modification of Tool Results in Injury (BSEE Alert)
During offshore energy operations, a worker was recently injured while attempting to install a hydraulic line on a pipe-handling machine. The worker determined that the combination wrench on hand was too long for this particular use and attempted to manually alter the tool by placing the wrench into a vice to shorten the length using a hacksaw. During the wrench alteration process, the worker cut a...
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no parking
Why "safety signs" often fail to elicit the behavior we need
Thanks to Ross W Skaggs, CSP (ret) , for another pic – follow him @ LinkedIn for more. Today’s pic will make you scratch your head and maybe wonder how that could happen. “No Parking” signs may be one of society’s most widely used signs.  They convey a simple directive, yet can you guess the #1 non-moving violation on our roadways?  Yep, parking violations. ...
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Fatal flaw in OSHA's "Periodic Inspection" requirements
We are all familiar with OSHA’s LOTO Periodic Inspection requirements (1910.147(c)(6)).  It is a topic of great debate, still in the Year 2023.  But there is a serious, I say it is a fatal flaw in the periodic inspection process. It is common for this activity to be performed by managers/supervisors who are authorized in the LOTO program and have direct supervision of the employees...
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KY-OSHA and the application of it's PRCS standard for Construction
When people say, “safety is just common sense,” I wish we could slap them.  Working for a client in KY, I have identified so much that is different between their state plan and the federal OSHA requirements.  Some of the differences just do not make sense and I am sure there are some political forces behind the lack of “risk sense” in these differences.  For example,...
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KY-OSHA 1st Aid Standard is very different from 1910.151
As with some state plans, KY-OSHA has some standards that are more in-depth than the federal version.  Although, a couple of years ago, the KY legislature passed a bill that restricts KY-OSHA from adopting any standards that are more stringent than federal OSHA.  But for now, KY-OSHA’s 1st Aid standard goes much further than federal OSHA. The employer shall ensure the ready availability...
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