One of the scariest things I have learned in my career, going all the way back to my days as a FF, was the when I learned about the “correction factor” that atmospheric monitors come with. I had used these devices for years, even entering some PRCS for “recovery” (sorry not many actual rescues as a FF – we usually show up too late!). But I have to give credit to Jeff Steen,...

Oily waste safety cans are an essential safety device where ever cloths and wiping rags are used with oils and solvents. Rags and cloths soaked with solvents, thinners, linseed oil, combustible adhesives, and other flammable liquids present a serious fire risk if they are improperly discarded. These cans have specially designed lids that open no more than 75° and stays closed when not in use, isolating...

This is another part of my recent respirator articles; my attempt to help up and coming program administrators understand what OSHA is actually requiring as the absolute minimums.  This post is about the “numbers” we see and hear when discussing respiratory protection.  As I posted a few months I ago, during an audit for a client we came across some emergency responders who had...

A couple of weeks ago EPA met the court’s decision by posting the amended RMP rule on the CFR.  This meant that those amendments that had dates that had come due were in full play.  But on May 30, 2018, EPA proposed changes to the final RMP Amendments rule issued on January 13, 2017. EPA is proposing to rescind amendments relating to: safer technology and alternatives analyses, third-party...

If I had a dime for everytime someone says to me… “where do you come up with all this sh_t?” during our deep discussions on process safety topics.  And whenever I do my 5-day Process Safety course we seem to always get deep into the “process safety weeds” and one topic that many students are amazed by is that there is a RAGAGEP for just about all of our needs. The...

ATTENTION FOOD PROCESSOR CLIENTS:  OSHA is onto the Clean-In-Place (CIP) process and how it contains “hazardous energy sources”, which in turn makes opening up the CIP system a “line-break” and LOTO activity.  These citations center around PPE and LOTO issues at a food plant where workers were exposed to “hot water”. OSHA has cited a food processor for...

I have so many of these incidents on video, investigation pics, investigation reports, OSHA citations, and yet the video’s, pics and reports continue to arrive in my in-box.  This one is quite something, but even after that awesome display of a flash fire exiting a manway like a rocket – anyone want to bet me that at some point they went right back to grinding/cutting on the vessel...

SAFTENG members, here are four ppt files that I used at my four-part series I did the past four months at the SW OH ASSP Chapter meetings.  We broke the sessions down into:  Evaluating spaces What makes a space a CS What makes a CS a PRCS Entry options (c)(5) Alternative Entry  (c)(7) Reclassification (d)-(k) Permitted Entry PRCS Entry Program and Permit Requirements Rescue Non-Entry...

Yes, as I posted a couple of weeks ago, the RMP Amendments are now in effect (at least those with compliances dates that have passed – some have dates further out).  One such requirement that seems to be causing a stir is “3rd Party Audits” for Program 2 and 3 Level RMP processes (e.g. 68.59 and 68.80).  LinkedIn and other social media platforms have less than scrupulous...

In this last part of 2018, I have been on a LOTO crusade; I have been to 12 different facilities since August to help them understand LOTO.  Some projects were complete new builds, some were to help with implementing Group LOTO, and a few were to training company safety professionals on the OSHA requirements so they can better understand the minimum requirements.  But not just over these...