According to OSHA’s 29 CFR 1910.333 standard, “Conductors and parts of electric equipment that have been deenergized but have not been locked out or tagged … shall be treated as energized parts.” Even below 240V, arc flashes can occur. The clothes you wear under your PPE are equally important. Molten metal –or the arc flash itself– may get beneath your PPE, only for a moment, and...

Those who follow my posts closely know I am a massive fan of bollards for physically protecting hazardous materials processes. These simple and inexpensive posts have saved my butt over my career more times than I can count, and yet so many still are unaware of their need and requirements. But these bollards are for “ground-level protection” from powered mobile equipment. Recently, I had...

Growing up in the Process Safety world with OHSA’s PSM and EPA’s RMP standards, I thought everyone had a “Safety Management System.” In school, we learned about OSH Management Systems and all they could do for a business. However, when I started consulting in 2005, I realized that SMSs were elusive in industrial facilities. Even those who had one in writing rarely actually utilized...

In light of the recent HSE video showing a 30′ silo exploding and going airborne for 9 seconds, I thought it might be fitting to offer some guidance on how to SAFELY perform HW on these “used containers.” OSHA’s 1910.252 standard provides no advice other than to say that we must be “absolutely certain” that the container is vapor/gas free. But the IFC, 3510.2, offers...

As you know, I am a big fan of the International Fire Code and utilize it more than outdated OSHA standards. One requirement the IFC has that OSHA does not is that “conspicuous signs shall be posted to warn others before they enter the hot work area.” Such signs shall display the following warning: … HomeRead More »

Combustible Dust was not included in Table 5003.1.1(1) because of the inherent difficulty in establishing a maximum allowable quantity (MAQ) and determining if and when the MAQ had been exceeded. An occupancy with an uncontrolled combustible dust hazard is classified in Group H-2 in accordance with Section 307.4 of the International Building Code (IBC), with the exception of certain woodworking uses...

Table 5704.4.2—Outdoor liquid storage in closed containers and portable tanks (see below) is often referenced when a business wants to store flammable liquids outside the main building. I wanted to take a second to explain the application of that table to those on the EHS team who may not be experienced with the OH Fire Code/IFC. Table 5704.4.2 –  Outdoor liquid storage in closed containers...

Due to all the support these past few weeks, I have been able to make another $500 donation to my Alma Mater, Murray State University’s Occupational Safety and Health Program. With this week’s donation, we are over $4,000 for the year. It was the second $500 donation to MSU this year. And yes, I believe in what they are doing at the MSU-OSH program. Your membership fees go back into the safety profession...

Question: Does 29 CFR 1910.135(a)(1) apply when employees are operating cranes that fall under 29 CFR 1910.179, Overhead and Gantry Cranes, and/or using jib cranes, monorail cranes or fix hoists, for lifting loads indoors and outdoors? Response: OSHA’s Head protection standard at 29 CFR 1910.135(a)(1) requires employers to ensure that each affected employee wears a protective helmet when working...

Scenario: A mobile ladder stand platform with steps will be constructed to access multiple CNC machine tables at a height of 40 inches measured from the floor. Question 1: What are the rise height, tread depth, and width requirements of mobile ladder stand platform steps? Response: The requirements for mobile ladder stand platforms are contained in 29 CFR § 1910.23(e), Mobile Ladder Stands and Mobile...

An HVAC technician uses a portable ladder to access a low-slope roof 12 feet high. The ladder is secured to the building and placed at a 4/1 angle. The side rails of the ladder extend three feet above the roof landing. The HVAC unit to be worked on is 25 feet from the roof’s edge. Question: When the employee steps onto the roof’s landing from the portable ladder and while the employee is...

Background: You state that as a Senior Mechanical Engineer for HVAC systems in Air Force facilities, you are responsible for setting design standards for mechanical systems in the facilities (primarily office buildings but also childcare, emergency operations, & dormitory-type buildings). In this capacity, you sometimes use HVAC systems that may expose facility occupants to the system’s refrigerant...