Managing our LOTO program requires considerable resources, and it requires a team approach! However, we see many failed attempts to control hazards through a facility’s LOTO program. One of the most common failures is how “authorized employees” are defined in terms of the skills they are trained on.  Which Rabbit Hole you choose to go down and how far you go down depends on the...

I put this image together for a friend struggling to demonstrate to their management that we can not discuss LOTO until Machine Guarding is in place. These two topics go hand in hand and trust me; if there are guarding issues, those hazards will be compounded when we attempt to frame up the LOTO program. Guarding is for the OPERATIONAL safety of the machine/equipment and, if not done well, poses a...

An Ohio subsidiary of one of the world’s largest automotive suppliers could have prevented a 26-year-old employee in Franklin from being fatally crushed in October 2023 if the company had provided proper machine guarding.  OSHA responded after being informed of the incident and learned the worker, on the job for about a year, was placing cardboard under a machine that bends vehicle exhaust pipes...

Are you tired of playing the OSHA Compliance game that requires us to “comply” with standards that are 50 years old?  The International Fire Code (IFC) is an excellent resource for taking your hazardous materials handling systems/processes to the next level.  The IFC is used or adopted in 42 states, including the District of Columbia, Guam, Puerto Rico, and the U.S. Virgin Islands. This...

There are two (2) types of Asphyxiants: Simple Chemical also known as Systemic These different types of asphyxiants behave differently and cause harm differently. … HomeRead More »

Chlorine is EXTREMELY HAZARDOUS, with an IDLH of 10 ppm and a TLV of 0.5 ppm (just above the odor threshold for most). Chlorine is heavier than air (VD > 2.5), and when released, it forms a greenish-yellow gas with a pungent, irritating odor that follows the terrain at ground level.  The mean odor threshold for chlorine lies between 0.2 and 0.4 ppm.  Chlorine is a NON-FLAMMABLE gas; however,...

An image from my HAZMAT courses… People wonder why the ERG Protective Action Distance diagram is shaped like it is. This image validates the model…                                       NOTE: Cl2 release image is from the Jack Rabbit testing project

Here is a GREAT “self-assessment” tool, just eight (8) questions, to evaluate your facility’s ability to investigate and perform causal analysis properly. … HomeRead More »

This is a crazy case!  The mill hired a contractor to build scaffolding inside one of its Chlorine Dioxide (CLO2) tanks.  The mill prepped the tank and even performed the initial air sampling of the space.  Turned it over to one of the scaffolding contractor employees who would be the attendant for the entry.  Three entrants and the attendant were wearing personal Cl2 air monitors. ...

As he had many other days, the morning shift welder arrived at 5 a.m. to work on Aug. 28, 2023. Tasked with doing some fabrication work in a 4-foot by 8-foot space in a ship’s hull, the employee began work unaware that fatal suffocation would soon end his life. Less than two hours after entering the ship, a supervisor found the unconscious welder and signaled for help, only to fall unconscious as well. A...

The Emergency Planning and Community Right-to-Know Act (EPCRA) requires businesses that store and/or manufacture, process, or use certain chemicals to complete the Tier II (EPCRA 311 and 312) Report and/or the Toxics Release Inventory (EPCRA 313) Report, also called the Form R. Section 112(r) of the Clean Air Act focuses on risk management for accident prevention. While these three (3) programs...

How do you differentiate between an amputation without bone and avulsions? … HomeRead More »