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Defending H. W. Heinrich's work... It is time to stop talking, roll up the sleeves, and go to work
When a situation exists that creates a loss of life, injury, and suffering; when it costs a king’s ransom annually; when its cure has been demonstrated to be practical; and when all are agreed that something can and should be done about it, it is time to stop talking, roll up the sleeves, and go to work.   Industrial Accident Prevention – A Scientific Approach, H. W. Heinrich, Assistant...
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OSHA says our ERT members traveling to an emergency at the plant is work activity “in the interest of the employer,” and was traveling as a “condition of employment”
Scenario: As part of their normal workday, an employee commutes in his personally-owned vehicle from home to the workplace. At the end of his 8-hour work shift, the employee commutes from the workplace to his home. Later that same day, there is an emergency at the workplace, and the employee’s supervisor calls him to return to work to assist with resolving the emergency. The employee starts driving...
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Human Failure Flow Chart HSE 08 27 22
In a BBSP the % Unsafe is more valuable than the % Safe
It is a standard error made in Behavior Based Safety Processes (BBSP)… we celebrate the % Safe while the real value lies in the % Unsafe.  I am all for celebrating the successes once they have been validated as real; however, to get the potential value from our BBSP, we need to utilize the unsafe behaviors to create a LEARNING CULTURE within our organizations.  Even when the unsafe...
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The state of Connecticut is passing a bill to require volunteer fire department or volunteer ambulance company to comply with Conn-OSHA
The state of Connecticut is passing a bill that would require a volunteer fire department or volunteer ambulance company to comply with the state’s Occupational Safety and Health Act (Conn–OSHA) as an employer, unless it is regulated by the federal OSHA law. By law, Conn–OSHA governs workplace safety for the state and its political subdivisions as employers; so, certain non–governmental...
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Congress sends letter to Seqens North America concerning their recent fatal explosion and previous accidents and compliance issues
Senators Markey and Warren and Congressman Moulton have sent a letter to Seqens North America seeking a response to many questions regarding the business’s past accidents and compliance issues.  In the early hours of Thursday, May 4, 2023, an explosion at the Seqens pharmaceutical manufacturing facility in Newburyport injured four workers, with a fifth worker unaccounted for in a facility...
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Hot work on small tanks and drums (UK's HSE)
The UK’s HSE has published a booklet to help manage risks when performing Hot Work (Welding, Cutting, Brazing) on “used containers”.  In the USA, OSHA has some very explicit language in their welding standards… 1910.252(a)(3)(i) Used containers. No welding, cutting, or other hot work shall be performed on used drums, barrels, tanks or other containers until they have been...
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OSHA's new NEP on Falls is not just for construction
This new NEP on falls covers: Roof top mechanical work/maintenance Utility line work/maintenance (electrical, cable) Arborist/tree trimming Holiday light installation Road sign maintenance/billboards Power washing buildings (not connected to painting) Gutter cleaning Chimney cleaning Window cleaning Communication Towers For other non–construction work activities where a worker is observed working...
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Defending H. W. Heinrich's work... The difference between blame (or guilt) and responsibility
We need to note the difference between blame (or guilt) and responsibility. A foreman need not hold himself morally guilty when an employee in his charge is injured, but he cannot and should not evade responsibility under any circumstances whatsoever. Remember that the authority to issue an order involves the responsibility to see that it is properly executed. The country depends upon you—the key...
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Safety Thought of the Week... Culture is generated through the collective experience of practices
Each time the site director has been confronted with a contradiction between safety and production, he has chosen to favor safety, or on the contrary, he has accepted to “adapt” safety rules to achieve a production target. Each time an operator reaches a production target but has taken a risk to do so, the management team will ask him not to do it again, or on the contrary may hold him up as a hero. Managerial...
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Now that the "safety stand-downs" have ended, what now?
As I wrote last week, I am not a fan of the so-called “safety stand-downs” that seem to be all the rage these days.  Our stand-downs in the 1990s and 2000s were entirely different approaches and were conducted following serious events.  My post spurred a lot of great discussions about how they are conducted vs. how they should be conducted and whether we can measure their impact. ...
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EPA EPCRA Survey 2023
Results of EPA's National Survey of State Emergency Response Commissions
I am sharing this report to highlight the weaknesses in the ability of the states to comply with the new emergency response exercise requirements in the RMP rule (40 CFR Part 68.96 Emergency response exercises). In October 2021, the Office of Emergency Management1 (OEM) of the U.S. Environmental Protection Agency conducted a survey of the State Emergency Response Commissions (SERCs) in each state and...
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If you're going to use lagging indicators, at least use them correctly
As the debate in OSH regarding metrics and lagging indicators rages on, there is one aspect to their use that far too many overlook.  If your organization is setting goals using lagging indicators, it should at least be using them correctly.  This means that BOTH FREQUENCY and SEVERITY need to be measured.  I am sure most of us have seen the weakness in measuring the overall injury/illness...
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