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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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Verification of Zero Energy State (ZES) and Specific Procedures
One of the more popular findings in our LOTO assessments/audits involves the lack of specific procedures for verifying a zero energy state (ZES) for EACH energy source.  The LOTO standard, 1910.147, makes it clear that the energy control procedure must be “specific.”… … HomeRead More »
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Catastrophic driveshaft failure on fire pump during weekly test
The Incident Details … HomeRead More »
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PRCS Rescue and Emergency Services (1926.1211)
As the debate continues to rage regarding the types of PRCS rescue and when they are required, OSHA has seen fit to publish the following: (emphasis by me) Effective emergency planning is vital to ensure that any entrant who becomes sick or is injured in a permit space can be evacuated quickly and safely. The entry employer’s permit space program must therefore include procedures for entrants to be...
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Alternate Procedures for Certain Permit Spaces — Section 1203(e)
This a followup to my earlier posting about OSHA LOI and using both Reclassifications and Alternate procedures on the same space at the same time.  I received a lot of questions from that post so I thought I would share the info I shared with those who contacted me.  This information is also directly from OSHA materials… (emphasis by me) … HomeRead More »
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Employers Seeking Relief Under Temporary Enforcement Guidance (Respiratory Protection)
It is important to understand that the temporary enforcement guidance memoranda do NOT offer blanket waivers or exemptions for complying with any OSHA standards or provisions of such standards, including the Respiratory Protection standard (e.g., annual fit-testing requirements). Rather, they allow for enforcement discretion by CSHOs during the COVID-19 pandemic period in circumstances where an employer...
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Entry into a space that is a PRCS REQUIRES a rescue plan and coordination with that team
Jonathan Zimmerman and I received some less than flattering feedback when I stated in our 2019 ASSP presentation that there are NO exemptions for NOT having a rescue plan for ENTRY RESCUE when the entry method is via a “permit” (1910.146 (d)-(k).  This single topic garnered more discussion after our session than any other – it seemed to catch a lot of folks off guard.  Of...
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Flammable Liquids, Combustible materials, and Pressure Vessels
We have had many discussions on SAFTENG regarding pressure vessel safety, but it is the Year 2020 and we need to have a very direct talk about how we manage flammable liquids and combustible materials around our pressure vessels.  In this article, I am primarily speaking to those in the Anhydrous Ammonia fertilizer industry and more specifically to those who are using the Nitrogen Stabilizers. ...
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OSHA issues PRCS citations at tank cleaning business after double fatality (single entrant, one would-be rescuer, $1.5M)
UPDATE from OSHA case file:  At 12:30 p.m. on February 20, 2020, Employee #1, employed by a structural steel fabricator and erector company, was entering a tank to clean it. The tank had a combination of Ecocure II and methyl ethyl ketone (MEK) residues and had been purged with nitrogen. Employee #1 entered the permit-required confined space that contained the residual chemicals and nitrogen to...
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Certifications or Technical abilities, which are more important for our profession?
Disclaimer: I am not a fan of certifications and I carry NONE – a proud safety rebel who has bucked the certification wrap my entire career, so consider the source of this advice. Rather than spending hundreds of hours preparing for the ASP/CSP/OSHT/CSHT/CHMM/CIH how about taking a training course or two from a REPUTABLE provider so that you obtain the skills necessary to better protect the workers...
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Are you an Anhydrous Ammonia distributor using Nitrogen Stabilizers?
If you are an NH3 distributor and you’re using the Nitrogen Stabilizers some things have changed that you need to be aware of.  First and foremost, see my posting with the Safety Alert from Transport Canada regarding the issues they have found regarding storage and transport tanks and these Nitrogen stabilizers.  I have not heard anything from a USA group or agency, but if it is happening...
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PRCS Attendants are a CRITICAL PATH for a safe entry - who are you allowing to fill your roles?
We have all seen it… the person assigned to be the PRCS Attendant (and Fire Watches suffer this infliction as well) are the youngest, weakest, least trained, least experienced, lowest paid, and most incapable person on the job/team. As I have written about before, one of my former employers actually but an age restriction on the role as we just grew tired of our field audits always finding some...
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Safety Advisory: Effects of additives in anhydrous ammonia nurse tanks or delivery tanks (Transport Canada)
In 2017 and 2019 I wrote about these Nitrogen Stabilizers and how their introduction into a PSM/RMP covered process would require a MOC and PSSR and I broke down the potential concerns and questions regarding these additives.  Now it seems there may be a Mechanical Integrity twist to the use of these additives, as Transport Canada has issued a Safety Advisory about using additives with anhydrous...
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