Here we have three (3) chemical labels, each one very different from the other and all three have a different agency/organization that oversees their use.  All three (3) are for the Category 3 Flammable Liquid Xylene, CAS# 1330-20-7.  The question is… Does it matter where/how these three (3) labels are used on containers of Xylene? I say, yes – VERY MUCH so, but what do...

For the SAFTENG members This is my 2019 version of the GHS HAZCOM and Behavior of Hazardous Materials training ppt. The course does what I like to call “Compliance to Science”; it covers OSHA’s GHS requirements and then gets into the behaviors of hazardous materials.  The course is intended to ensure that users of SDS’s can actually use the data provided on the SDS and...

Today, OSHA announced it is requesting information on a possible update to the Control of Hazardous Energy (Lockout/Tagout (LOTO)) standard. The Agency is interested in comments on the use of CONTROL CIRCUIT-TYPE DEVICES to isolate energy, as well as the evolving technology for ROBOTICS.  OSHA is requesting information about how employers have been using control circuit devices the types...

A Reminder to Minimize Process Shutdown Related Releases and to Report Releases In a Timely Manner Introduction Unlike some other natural disasters, the onset of a hurricane is predictable and, as a result, lends itself to early preparations for minimizing its effect on a facility. Before hurricane force winds and associated storm surge flooding can damage...

Sprinklers save lives and they save billions of dollars each year from fire losses; however, if a head is activated accidentally, we can suffer serious damage from all the water and the downtime.  So protecting our heads from accidental discharge is as important as protecting them from contamination and delayed activation.  In this article, I would like to discuss the question I get...

The “Swiss Cheese” model developed by James Reason is an example of the epidemiological model.  This is a complex, linear cause-and-effect model where accidents are seen as the result of a combination of active failures (unsafe acts) and latent conditions (unsafe conditions) … HomeRead More »

This is a simple, linear cause-and-effect model where accidents are seen as the natural culmination of a series of events or circumstances that occur in a specific and recognizable order. The model is often represented by a chain with a weak link or a series of falling dominos. In this model, accidents are prevented by fixing or eliminating the weak link, by removing a domino or by placing a barrier...

Car Seal  Lockout/Tagout (LOTO)  For OPERATIONAL CONTROL of  valves For MAINTENANCE & SERVICING CONTROL of energy isolation devices … HomeRead More »

This picture represents the fun side of working with clients who want to be world-class and meet the “intent” of a code or standard, not worrying if it just meets OSHA.  This is a refrigeration client who is really trying to make this start-up an example for other facilities within the organization to emulate.  During a Pre-PSSR (before the official PSSR) we came across...

Emergency Escape Breathing Apparatus (EEBA) have been around my entire career and I have used the mouth-bit style and the supplied air bag-over-the-head style.  Actually, I have never had to use one, but I had them at my facilities when I was a Safety Manager in the chemical and semiconductor industries.  So I have learned to hate these devices!  One day I suggested we remove them from...

Question 1: If an employer pays for and allows respirators to be worn on a voluntary basis when respiratory protection is not required to meet any OSHA standard, is it then regarded as though the employer is mandating the use of the respirators? … HomeRead More »

The quick and easy answer is YES and before the changing of Presidential administrations the wheels were in motion, even after several court set-backs.  But some would like to accuse me of being a “consultant” and spreading fear to drum up business.  I used to laugh off these comments and accusations, but today I received a call on my way home from a great day of training that...