Way back in February 2016 I introduced many of you to ISA-RP12.12.03, Standard for Portable Electronic Products Suitable for Use in Class I and II, Division 2 for the first time and I received many e-mails, texts, and phone calls about those 2016 posts.  Although the posts were speaking to smaller electronic devices, most notably “fitness bands”, the concept rubbed a lot of folks...

This is awesome. Cavitation has been the end of many pumps in my career and the causes of some significant LOPC events, but to see it be created and watch it in clear pipes and pumps is the way to learn. This short video should be in every operator’s training!! … HomeRead More »

This 2020 LOI rescinds the letter issued on July 25, 2019, to Ms. Hill, by removing the parenthetical in the second paragraph of the background section.  This is an interpretation regarding a possible conflict on the minimum separation distance between aboveground liquefied petroleum gas (LPG) containers and buildings in OSHA’s 29 CFR § 1910.110 – Storage and Handling of Liquefied Petroleum Gas...

Someone requested OSHA to address the growing field of virtual reality safety and health training. Their letter constitutes OSHA’s interpretation ONLY of the requirements herein, and may not be applicable to any questions not delineated in the original correspondence. Your paraphrased questions and our responses follow. Question: We have been told online, commercially available, training tools meet...

OSHA’s latest position on testing electrical gloves is very enlightening!  For example, even if the gloves are simply electrically tested and then returned to storage, OSHA regards the gloves as being issued for use!  This is a new one on me, but in their latest LOI they discuss the following scenario: gloves got tested on January 1, 2020, but not issued until October 1, 2020 must they...

No, the employer is not required to include findings and recommendations from the facility siting study report in the same PHA worksheet or recommendations log to comply with 29 CFR § 1910.119(e)(5) and 29 CFR § 1910.119(e)(7). … HomeRead More »

As I always say, we can not discuss MOC and PSSR as if they are separate systems… they go hand in hand 99% of the time.  That is what I want to discuss: how a PSSR requirement defines how we manage our MOC system.  We have discussed many times there are ONLY TWO (2) occasions where OSHA and EPA require a PSSR to be conducted: new facilities, and modified facilities when the modification...

At approximately 4:00 a.m. on March 29, 2020, an employee was installing a blind on a flange on a reactor. Then, the probe stem fell inside of the reactor, and the employee tried to fish it out. Using a ladder, the employee went inside the reactor that was NOT cleared for entry because the reactor still contained vinyl chlorine. Halfway down the ladder, the employee became dizzy and fell to the bottom...

Buckle up buttercup… the political winds in DC are shifting and with this comes “opportunities” – man how I hate politics!  For those of you who may have thought that the RMP Amendments from the final year of the President Obama administration were long gone – THINK AGAIN!  On Friday (12/4/20), the U.S. Court of Appeals – D.C. Circuit granted a request...

On the plate heat exchanger, a machined nut backed off on the flange bolt that holds the gasket in place. This caused part of the gasket to blow out resulting in ammonia (NH3) to leak into the machine room. The machinery room alarm was activated.  Upon inspection, the following failures were found: … HomeRead More »

The word “potential” is defined by Merriam-Webster as: existing in possibility : capable of development into actuality In OSHA’s PRCS standards (both 1910 and 1926 versions) it uses the word “potential” when talking about atmospheric hazards; especially when we are talking about RECLASSIFYING a PRCS to a NON-PRCS using 1910.146(c)(7) or 1926.1203(g) 1926.1203(g)(1)...

This draft guidance document is intended to clarify to the public regarding existing pipeline safety standards. The contents of this document do not have the force and effect of law and are not meant to bind the public in any way, but pipeline operators must comply with the underlying safety standards. (emphasis by me) … HomeRead More »