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I am proud to announce that SAFTENG and The Chlorine Institute have renewed our partnership for another year (through 2026).  Members of The Chlorine Institute receive a FREE SAFTENG membership.  If you qualify, please contact me

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oct 7 2022 fatality alert
PRCS Engulfment Fatality inside dust collector/air separator (MSHA)
MINE FATALITY – On October 7, 2022, a mechanic was fatally injured when engulfed in the material after entering an air separator to clear a blockage. Best Practices … HomeRead More »
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"Distance" as a passive mitigation measure
Last week I wrote about how either distance or a barrier is necessary to CONTROL hazards.  OSHA’s made a great case in 2020, explaining how the separation distances in 1910.110 is a PASSIVE MITIGATION measure.  (emphasis by me) OSHA concludes that NFPA 58 (2017), Sections 6.28.2 and 6.28.3, do not provide an equivalent level of safety as provided by the greater separation distance...
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Potential vs. No Potential
Defining and Quantifying "potential hazardous atmosphere"
Recently a trade organization issued a guide on working in Permit Required Confined Spaces specific to their industry.  The organization took a sentence from NFPA’s Guide on Confined Spaces (NFPA 350) and used it as justification to circumvent OSHA’s minimum standard on entry into PRCSs (1910.146 and 1926.1201-.1213).  l have received over a dozen questions regarding this “guide”...
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RegO issues "WARNING" on Retesting Pressure Relief Valves for ASME Containers
As stated in REGO’s Warning Document… Simply retesting pressure relief valves manufactured by RegO that have been in service for several years to confirm conformance with start-to-discharge and reseal ranges does NOT guarantee that the valve is suitable for continued service. Or that the valve will perform as designed at nominal pressures or in emergency conditions. The environment in which...
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RegO issues guidance on Pressure Relief Valve Inspection and Maintenance
“Relief valves should be inspected each time the container is filled but no less than once a year. If there is any doubt about the condition of the relief valve, it must be replaced.” Major Factors to determine the “Life” of Relief Valves include: Water/Ice Accumulation Corrosion Dirt – Debris Damage Normal Aging Eye protection must be worn when inspecting relief valves under pressure. Never look...
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Where we store our LEVEL A suits matters (Max Storage Temp)
The old debate has been settled by the largest provider of LEVEL A suits.  Many organizations store their emergency response gear in a trailer that is parked (usually) outside on the property.  Although OSHA does not mention this level of detail, the manufacturer has now established the maximum temperature at which their suits may be stored… … HomeRead More »
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1910.253
Flashback arrestors are PROTECTION devices, not prevention devices
In a recent discussion regarding an accident with a Fuel-Oxy Torch system, I had some discussions about the layers of protection and the Prevent-Protect-Mitigate safety model using the Hierarchy of Controls (Elimination, Substitution, Engineering Controls, Administrative Controls, and PPE).  The event did NOT involve a flash-back, but I used the flash-back requirements to demonstrate the difference...
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Equipment Opening gone bad (NH3 Heat Exchanger)
On February 19, 2022, Employee #1 took apart an active heat exchanger. While doing this, 419 pounds of ammonia were released, causing upper body burns to the employee. The employee was hospitalized for treatment. … HomeRead More »
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Equipment Opening gone bad (System Applicator)
At 3:10 p.m. on February 2, 2022, an employee, 26, was performing maintenance on a System Applicator. The employee began the ammonia bleeding procedure wearing safety glasses and rubber gloves. After approximately 20 to 30 minutes, the employee no longer heard a whistling sound and believed that the system was completely bled out. When the employee removed the filter cap, the remaining anhydrous ammonia...
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SDS Section 2
HFO-1234yf is still a PSM HHC, even with a revision of the SDS
It seems the games may never end with HFO-1234yf and it’s designation as a Highly Hazardous Chemical (HHC) within the Process Safety Management Standard.  A friend of a friend in the automobile manufacturing industry contacted me about their use of this new refrigerant.  The friend/client shared all of my previous articles explaining how HFO-1234yf is a PSM-covered chemical.  But...
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The horrors of improper LOTO
When workers say to me, “that hardly ever happens” I just shake my head.  It happens far more often than most people think.  I mean, think about why did OSHA promulgate the LOTO standard – people were turning on machines with workers inside.  But this case was exceptionally bad!  A father found his son inside a ribbon blender without LOTO being applied.  He...
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Understanding hazardous gases
A fine example of how the safety profession has drifted from science is the vast misunderstanding of hazardous gases.  From their hazards to their behaviors, we have a lot of myths and misconceptions about hazardous gases.  Sadly, the fact that OSHA does not have a “flammable gas” standard plays a role in this situation – hence we have a profession too dependent on OSHA...
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