There has been a lot of public debate about OSHA’s attempt to update its emergency response standards.  And in this debate there has been a lot of misinformation shared across municipal and private fire brigade groups in what OSHA is actually trying to implement.  This document, from OSHA, is a compilation of the questions posed and issues raised in the Notice of Proposed Rulemaking...

Respondent operates a facility to manufacture chlorine, bleach, and hydrochloric acid. At all times relevant to this CAFO, Respondent produced, used, or stored more than 2,500 pounds of chlorine at the Facility and was subject to the requirements of CAA § 112(r)(7). At all times relevant to this CAFO, Respondent produced, used, or stored hydrogen at the Facility and was subject to the requirements...

Recently, I had the pleasure of working with one of my international clients at several locations.  This is in thanks to Paul A. for putting his trust in me throughout my career.  Paul and I met in Omaha, NE, in the late 90s and formed a professional and personal friendship as he is ALL ABOUT SAFETY guiding business decisions.  We worked for a man I have mentioned numerous times, Dale...

Much of my work involves helping clients achieve more than “compliance” with minimum government standards.  I typically do this using RAGAGEPs; however, those may be too much to handle in some situations.  So, I will propose another government standard that applies to the process/hazard.  For example, unloading flammable liquid railcars.  Canada has some of the most...

This is safety satire on a Friday afternoon after a long week! I may not be a Certified Welding Inspector (CWI) or a Visual Level II inspector certified per ASME V Supplemental NDE Certification requirements. Still, I believe API 570, Section 8 Repairs, Alterations, and Rerating of Piping Systems allows only a dozen or fewer radiator hose clamps in repair specifications.  I may be slightly off,...

From OSHA’s summary of the Final Rule: Heating, Air-conditioning, & Refrigeration Distributors International (HARDI) asked OSHA to update its Process Safety Management standard (PSM), 29 CFR 1910.119, to reflect this change once this rule is finalized (Document ID 0355, p. 2).  HARDI’s comment is out of scope for this rulemaking, which pertains solely to updating the HCS. However,...

OSHA is amending the Hazard Communication Standard (HCS) to conform to the United Nations’ Globally Harmonized System of Classification and Labelling of Chemicals (GHS), primarily Revision 7 (Rev. 7), address issues that arose during the implementation of the 2012 update to the HCS, and provide better alignment with other U.S. agencies and international trading partners, while enhancing the effectiveness...

I have spent much time with clients doing “Engineering and Code Reviews.”  These have been instrumental in avoiding many issues when it comes time for the INITIAL PHA. Depending on the process size and complexity, these can take 0.5 – 3 days, but that time is spent ensuring the primary containment systems and all the layers of protection that come into play for the PREVENTION-PROTECTION-MITIGATION...

It is rare; I can not recall ever disputing NFPA in any of their guides/standards/codes.  However, section 27.7 of NFPA 30 is worded incorrectly and needs to be called out as it poses significant risks if followed by the letter.  Section 27.7 covers the pressure and leak testing of “flammable liquid” piping circuits.  Although I am thankful for NFPA including this in NFPA...

May 2, 2024 MEMORANDUM FOR: REGIONAL ADMINISTRATORS STATE DESIGNEES THROUGH: AMANDA EDENS Deputy Assistant Secretary of Labor for Occupational Safety and Health FROM: SCOTT KETCHAM Acting Director, Directorate of Enforcement Programs LEE ANNE JILLINGS Director, Directorate of Technical Support and Emergency Management SUBJECT: Enforcement Guidance Under OSHA’s Recordkeeping Regulation When...

The National Institute for Occupational Safety and Health (NIOSH) has honored a request by Honeywell International Inc. to voluntarily rescind two NIOSH respirator approvals issued to Honeywell International Inc. Due to the voluntary rescission of these NIOSH approvals, respirators bearing these NIOSH approval numbers MAY NO LONGER BE USED, manufactured, assembled, sold, or distributed. As of...

The Department of Health and Human Services (HHS) proposes to amend regulatory requirements that would be used by the Centers for Disease Control and Prevention’s (CDC) National Institute for Occupational Safety and Health (NIOSH) to test and approve Combination Unit Respirators (CURs).  NFPA defines a CUR as… … HomeRead More »