If we spend enough time in chemical plants, we will encounter a widespread, albeit severe, human failure regarding a “safety-critical instrument.”  I am referring to the IMPROPER placement of personal gas monitors.  Nine times out of 10, where do we find these personal gas monitors on the worker’s body?  I am betting your experiences are similar to mine and you would...

The EPA’s revisions of its Risk Management Plan requirements regarding emergency drills have gotten much attention.  However, they were always a bit behind when it comes to the International Fire Code.  And need I remind those of you reading this that many states have adopted the IFC in some form. A Group H occupancy is defined as: Group H, High-hazard. High-hazard Group H occupancy...

In a 2024 LOI, OSHA reiterated its position that an Eyewash (EW) station must be capable of delivering 15 minutes of water flow. This means these EW bottles are NOT an “approved” EW station. Even the double barrel wall mount with two (2) squirt bottles does not meet the minimum flow rates. However, OSHA has stated that these squirt bottles CAN help flush a worker’s eyes; they just...

OSHA will not issue citations to an employer that properly uses a non-metal guard so long as the guard is constructed of a substantial and suitable material. OSHA standard, 29 CFR § 1910.219(m)(1)(i) states: Standard conditions shall be secured by the use of the following materials. Expanded metal, perforated or solid sheet metal, wire mesh on a frame of angle iron, or iron pipe securely fastened to...

The investigation found that they were processing hand sanitizer bottles by shredding them and separating the plastic from the hand sanitizer. During this process, a spark was created from the machine, which initiated a minor explosion and fire. The business has refuted the fire chief’s official account, saying, “There was no explosion at the site.“ “There was a loud noise,...

This can be related to process vessels, hoppers, pits, etc.- just about any “open-topped” space. Now, when it comes to hoppers, these will fall into the PRCS category based solely on their design with “inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross-section.” But even then, a very shallow hopper does not pose the same hazards by its...

OSHA found an animal food producer exposed employees to the risks of explosions, fires and long-term respiratory illnesses from excessive amounts of airborne dust, among two dozen safety and health violations they identified. The findings follow an inspection after the agency received complaints of unsafe working conditions. OSHA inspectors found the company’s poor housekeeping, its failure to...

One of the acceptable “protection techniques” for electrical enclosures within a Hazardous Location is to “pressurize the enclosure.”  Here are the three (3) Types of Pressurized Enclosures and the HAZLOC they are permitted to be used, and their design basis: NFPA 70, 500.7, (D) Purged and Pressurized. This protection technique shall be permitted for equipment in any...

As I have mentioned a few times, there is a substantial difference between a Safe Work Practice design to make OSHA happy and one that functions as a “management system” for the risk the “program” is trying to control.  Far too many “safety programs” are simply regurgitating the OSHA standards they intend to comply with. Sometimes, we come across a cut-and-paste...

The respondent owns and operates a single-site aerosol can manufacturing facility that uses, stores, and handles Isobutane (CAS# 85-28-5), a regulated substance, at the Facility in amounts over the threshold quantity for Isobutane of 10,000 lbs. The facility used, stored, and handled Butane (CAS# 106-97-8), a regulated substance, at the Facility in amounts over the threshold quantity for Butane of...

The following are my tips to ensure PRCS are properly ventilated when necessary.  Far too often, ventilation is nothing more than a “nice effort,” which can lead to disastrous results.  So, in my time in safety at petrochemical and semiconductor facilities, the safety team managed the ventilation equipment (blowers and flexible ductwork). Still, the entry supervisor was responsible...

I was working on another PRCS Entry program this week and thought I would offer some tidbits I include in my programs regarding: Space Isolation Atmospheric Monitoring My programs are lengthy and are intended to include every aspect of managing the risks associated with working around and inside PRCSs. SPACE ISOLATION ALL connections to a confined space that can convey a hazard to the space MUST be...