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OSHA citations for PRCS Fatality in Gasoline Storage Tank (Flashfire)
At 2:00 p.m. on September 20, 2019, an employee was inside of a 10,000-gallon fiberglass gasoline storage tank and was draining some brine water while cleaning the tank. The employee used a drill while inside the tank and ignited the gasoline vapors, exploding it and setting it on fire. The employee was caught in the explosion and was killed.  The environmental company has received seven (7) serious...
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OSHA citations for flash fire and exposure hazards of toluene ($183K)
OSHA has cited a carpet restoration, plumbing, and resurfacing contractor for exposing employees to safety and health hazards after a fatal incident at a worksite. The company faces $183,127 in penalties.  OSHA initiated an investigation after an employee suffered fatal injuries after inhaling lacquer thinner, which was used to resurface a bathtub. OSHA cited the company for failing to evaluate...
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Table A11.2.1 General Concept to prevent and mitigate dust explosions
Combustible Dust and the 8th Revision of the Globally Harmonized System of Classification and Labelling of Chemicals (GHS)
The United Nations issued its 8th Revision to the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) late last year and in this 8th revision we have some very good guidance on Combustible Dust (COM DUST).  For the record, OSHA is considering adopting the 7th Revision; we currently are using the 3rd revision in our 1910.1200 compliance.  So this is not so much about...
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When ventilation is your engineering control, it should meet IMC Section 500
When we have a hazardous material that poses either a physical hazard such as a flash fire/explosion or a health hazard we need to manage this hazard using our hierarchy of controls.  The first control is to see if we can use a “safer alternative” which we call “Elimination/Substitution”.  But if this is not possible we go to our next layer – Engineering Control(s)...
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Hand sanitizer fire hazards (2 videos)
In the past several weeks I have tried to explain the fundamental safety practices of storing the alcohols many businesses are using to make hand sanitizer.  This post I wanted to share two videos that show the flammability of these hand sanitizers and an excellent video from NFPA about how the changes at businesses such as distilleries may, in fact, place them at a higher risk as the concentration...
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EPA RMP citations @ WWT facility (Chlorine & $8K)
NOTE:  I have always said city/county governments get huge breaks in $’s when it comes to RMP citations.  A private company who performed this poorly in an inspection would have gotten 10X’s the citation $’s. On November 9, 2016, an authorized EPA representative conducted a compliance inspection of the Water Treatment Plant (“Facility”) to determine its compliance...
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EPA RMP citations @ polystrene foam production facility (Butane & $71K)
At its stationary source, the Respondent operates a Polystrene Foam Production facility using butane and has 132,235 pounds of butane in onsite storage. At its stationary source, the Respondent has one RMProgram level 3 covered process, which processes butane in an amount exceeding its applicable threshold of 10,000 pounds. On August 30, 2018, the EPA conducted an onsite inspection of the RMProgram...
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OSHA Expands Temporary Guidance for Respirator Fit-Testing to All Industries during COVID-19 Pandemic
OSHA has expanded temporary guidance provided in a March 14, 2020, memorandum regarding supply shortages of N95s or other filtering facepiece respirators (FFRs) due to the COVID-19 pandemic. This expanded guidance applies to all workplaces covered by OSHA where there is required respirator use. OSHA field offices will exercise enforcement discretion concerning annual fit-testing requirements, as long...
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Interim final rule to update the regulatory requirements NIOSH to test and approve PAPRs
The Department of Health and Human Service (HHS) is publishing this interim final rule to update the regulatory requirements used by the Centers for Disease Control and Prevention’s (CDC) National Institute for Occupational Safety and Health (NIOSH)to test and approve air-purifying particulate respirators for use in the ongoing public health emergency. With this rulemaking, parallel performance standards...
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Fire Code and CLOSED and OPEN Systems
I have written several articles lately explaining the limitations of storing flammables and toxics.  A couple of these articles referenced the International Fire Code (IFC) which is my favorite safety code for hazardous materials.  OSHA’s 1910.106 is from the 1969 NFPA 30 and has not been sustainably updated since; whereas the IFC gets updated every three (3) years.  In the IFC...
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Expanded Temporary Enforcement Guidance on Respiratory Protection Fit-Testing for N95 Filtering Facepieces in ALL Industries During the Coronavirus Disease 2019 (COVID-19) Pandemic
This memorandum expands temporary enforcement guidance provided in OSHA’s March 14, 2020, memorandum to Compliance Safety and Health Officers for enforcing annual fit-testing requirements of the Respiratory Protection standard, 29 CFR § 1910.134(f)(2), with regard to supply shortages of N95s or other filtering facepiece respirators (FFRs) due to the coronavirus disease 2019 (COVID-19) pandemic.[1] The...
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Appendix A Horizontal Vertical Standard Flow Chart
What is a Vertical Standard vs a Horizontal Standard?
These two terms are often discussed on OSHA outreach training courses, but I hardly ever mention them as they are more “legal” terms than safety terms.  But this month, MI-OSHA issued guidance to their CSHO’s which I thought did a really nice job explaining what these terms mean and how they are used in issuing citations.  Vertical Standards – Standards that apply to a particular...
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