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Different use requires different end-of-service-time indicators (EOSTI)
Last week I asked my FaceBook Group a “trick question” regarding the end-of-service-time indicator (EOSTI) on our Supplied Air Respirators that we use for emergency response.  I was so pleased to get so many texts/calls/emails and even a few phone calls checking to see if I was feeling OK.  I did not tell the group it was a trick question, but a lot of them realized there was...
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Double Fatality in sewer manhole, 2 entrants, rescue unsuccessful
At 4:41 p.m. on July 24, 2020, Employees #1 and #2 set a 32-foot ladder into an eight-and-a-half-foot manhole that was connected to the main city sewer line station. Employee #1 entered the manhole and was immediately overcome by hydrogen sulfide gas, Employee #2 entered and was also overcome by the gas. … HomeRead More »
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OSHA issues PRCS Construction citations after 1 entrant and 1 would-be-rescuer died from H2S
At 11:30 a.m. on July 9, 2020, Employees #1 and #2 and their foreman, employed by a waste management company, were installing a closed-circuit television (CCTV) into an 8-inch sewer line to enable inspections in the manhole. They did NOT test the atmosphere before attempting to enter the manhole, which met the definition of permit-required confined space, and ventilation equipment was NOT available....
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When life saving devices take a life - RISK is everywhere
At 8:30 a.m. on May 13, 2020, Employee #1 and Employee #2 were working to pressurize portable fire extinguishers. At some point, the extinguisher being worked on by the Employees exploded. Both Employees received severe lacerations to unspecified parts of their bodies. Employee #1 was killed, and Employee #2 was hospitalized due to his injuries.  OSHA Case File
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Chlorine LOTO Release
Improper isolation of a 1/4 turn ball valve leads to a reportable release of Chlorine
A manual ¼ turn ball valve (#1) was the lead isolation valve in a Double Block and Bleed arrangement.  The valve handle was incorrectly secured using a run of pipe BELOW the valve.  As shown, the valve handle would swing down in order to OPEN the valve.  With the chain securing the valve on the piping below it, it was not secured in its SAFE/CLOSED position.  The bleed valve (#3),...
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Strapless N95 NIOSH
Knowing the limitations of your respiratory protection is CRITICAL!
A few weeks ago a client asked me to review a new N95 Filtering Face Piece (FFP) respirator they had received from a salesperson.  This new N95 was very unique and it was touted to be NIOSH approved while being a “strapless” FFP.  I was confused, how can a NIOSH N95 FFP be “strapless”.  To say the least I had some serious doubts, especially knowing there are millions...
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A CS rescue team that is equipped only with traditional SCBA’s is not a CS rescue team by any measure!
One of the things that drive me INSANE during an audit or hazard assessment is a PRCS rescue team that is equipped only with SCBA’s.  To this day, I have ALWAYS been able to find an entry portal that is too small for a rescuer wearing an SCBA to pass through.  It then takes me several more minutes to find a closed permit for said space and the rescue plan was to use the on-site rescue...
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Permit-Required Confined Space rescuer training; 8, 12, 24, or 40 hours?
I have been working with a client on developing their PRCS Rescue team and of course, we get to the final phase, training the team, and the questions begin with how long is the training.  Now, the topic of training and its time commitment was discussed a long time ago; even before they decided they wanted their own team, as I always make sure my clients understand fully what it literally means...
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Incorporated by Reference (IBR) database
Incorporated by Reference (IBR) is the act of including a second document within another document by only mentioning the second document.  This act, if properly done, makes the entire second document a part of the main document. Incorporation by reference is found over 1,445 times in OSHA standards, with 949 being related to the General Industry Standards.  A lot of these go all the way back...
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Kansas Department of Agriculture updates its Anhydrous Ammonia Storage Tank policies (2/13/2021)
The following policy updates apply to anhydrous ammonia storage tanks (tanks) in the state of Kansas as of 2/13/2021.  The state has issued new retirement dates for the “railcars” that have been modified and used as fixed storage tanks for decades. This policy is intended to apply to the Fertilizer Industry within the state.  It does not apply to ammonia refrigeration vessels. The...
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GAO OSHA recordkeeping 2021
Actions Needed to Improve Reporting of Summary Injury and Illness Data (2021)
GAO’s analysis of Occupational Safety and Health Administration (OSHA) data showed that the number of recordkeeping violations OSHA cited fluctuated over 15 years. An April 2012 federal court decision (that effectively limited the time period for citing these violations) and a January 2015 expansion of OSHA’s rule for reporting severe injuries and illnesses coincided with and were cited by, OSHA staff...
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FAR FS 2021
FAILURES of true "facility siting" - our "zoning" process is broken and dangerous!
Having spent my entire safety career in chemicals, I have always been amazed when communities rezone and permit housing developments such as apartments/condos with high density populations within spitting distance of chemical/processing facilities and then the city officials are furious when there is an event that causes disruption in these housing developments.  This story is a PERFECT EXAMPLE...
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