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How a machine safe guarding device is for production and not for maintenance
It is important to emphasize that the machine guarding requirements of 29 CFR Part 1910, Subpart O standards COMPLEMENT THE REQUIREMENTS for LOTO. In some instances, an employer may avoid the requirements of the LOTO, if they ELIMINATE exposure to servicing and maintenance hazards by using machine guarding techniques compliant with those standards.   It is also important to...
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The basics of Lockout/Tagout starts with Machine Guarding
Lockout/Tagout (LOTO) STARTS WITH machine gaurding. Yes, MACHINE GAURDING – we can not even begin to speak of LOTO until we first have the forms of hazardous energy properly gaurded for our NORMAL OPERATIONS.  Because when the machine/equipment is being used for its inteded purpose(s) (e.g. Normal Operations) we are FIRST REQUIRED to ensure that all forms of “hazardous energy”...
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NJ's Toxic Catastrophe Prevention Act (TCPA) Program Update
The state of NJ has developed a Toxic Catastrophe Prevention Act (TCPA) Program Update intended to assist regulated TCPA facilities in understanding how they are impacted by the January 13, 2017, amendments to EPA’s RMP Rule, 40 CFR Part 68. The table indicated the effective dates of the amendments, which provisions are incorporated by the TCPA Program, the actions required by TCPA registrants,...
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The typical Safety Inspection responses (Video)
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EPA RMP citations @ semiconductor plant (HCL and 12 General Duty EHSs & $229K)
This Consent Agreement and Final Order serves as notice that the EPA has reason to believe that Respondent violated the General Duty Clause set forth in Section 112(r)(1) of the CAA and the Chemical Accident Prevention Provisions in 40 C.F.R. Part 68 and that Respondent violated Section 112(r) of the CAA. Respondent’s Facility has ceased all operations. On or about May 15 -17, 2017, the EPA conducted...
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HAZWOPER training credentials - it ALL matters!
There are not very many OSHA standards that call out the “trainer qualification(s)” for those who teach on the subject matter, but the HAZWOPER standard does.  When a trainer uses the phrase HAZWOPER over and over but does not recognize this is an acronymn that stands for Hazardous Waste Operations and Emergency Response, has no emergency response background, and/or has never received...
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OSHA's official position on LOTO-AFFECTED PERSONNEL
WOW… my LOTO ppt for “Affected Personnel” that I posted earlier this week has caused quite the “back and forth” with too many people/sites.  I just assumed that we had a basic understanding of “who falls into the “affected” bucket” and “what they must know”.  Affected employees do NOT need to attend a 2-hour training course...
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NFPA 51B - 2019 Updates to Fire Watch and Fire Monitoring Requirements
Many of us in the PSM/RMP arena use NFPA 51B as our Hot Work Safety Standard, rather than 1910.252(a) and with that said I thought I should update us on NFPA’s 2019 edition of 51B which includes several key improvements.  Probably the biggest changes from the 2014 edition are: the term FIRE WATCH is now officially defined, the FIRE WATCH TIME PERIOD after completion of hot work...
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Emergency Pressure Control Systems (EPCS) and Car Seal Program
One phrase that drives me crazy while working with my friends in the Ammonia Refrigeration industry is, “Come on, Bryan; we’re not a refinery or chemical plant; that is unnecessary here.”  For example, recently, we were asked to aid in an investigation into a reportable release from a PSM/RMP-covered process, and during our review of what happened, the facility failed to mention...
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LOTO Affected Personnel Training (.ppt)
   
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OK is just NOT good enough in Safety
We all know we, as safety professionals, see life through a different lens than most others.  But ever since I started seeing these AT&T commercials “Ok is just not good enough” I always go back to my HAZMAT ER days.  One of the last ER’s I was called upon for assistance, I was delegated to a non-official position because the local powers made it clear “we...
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EPA RMP citations @ food plant (NH3 & $34K)
Respondent operates an ammonia refrigeration plant and has on-site for use, 130,000 pounds of ammonia for cold food storage. Respondent has submitted and registered an RMPlan to the EPA for its stationary source and has developed an RMProgram accidental release prevention program for the stationary source’s single RMProgram level 3 covered process. On November 8, 2017, the EPA conducted an onsite...
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