A couple of weeks ago, I wrote about how the Process Safety Information (PSI) “Safe Upper and Lower Limits” will differ from those “Safe Upper and Lower Operating Limits” found in our Operating Procedures.  The article needed to be written as it received over 10,000 hits, and the e-mails continued with positive comments and more questions.  Several have asked for a real-life example of how...

PSM Retail Exemption Interim Enforcement Policy Employer(s) with employee(s) exposed to PSM-covered processes formerly exempted under OSHA’s 1992 interpretation of “retail facility” now must comply with the requirements of 29 CFR 1910.119 if the facility, or portion of the facility processing the highly hazardous chemical, does not fall into the North American Industrial Classification...

HAZCOM labeling is not intended to be a “process of elimination”!!!! 

WARNING!  NOT GRAPHIC, but you will witness three men loosing their lives in this electrical accident.  Notice how quick and quietly these men loose their lives to 13,700 volts!  

Memorandum For: REGIONAL ADMINISTRATORS AND STATE PLAN DESIGNEES THROUGH:  DOROTHY DOUGHERTY, Deputy Assistant Secretary From:   JAMES G. MADDUX, Director, Directorate of Construction Subject:  Temporary Enforcement Policy for Residential Construction Work in Confined Spaces … HomeRead More »

I am posting this to merely share the news, BUT PLEASE remember a worker DIED in this accident, so from a SAFETY PERSPECTIVE we really should not give a rats ass as to what a court found and reversed the OSHA citation.  This posting is NOT intended for “ammo” to show we do not have to guard our lathes, but rather to GUARD our lathes to save a life! … HomeRead More »

Respondent is the owner and/or operator of a facility which operates as an aluminum chloride manufacturing Facility.  On December 3, 2013, EPA conducted an inspection at the Facility to determine, among other things, Respondent’s compliance with Section 112(r) of the CAA. The Inspection included discussions with Facility representatives concerning the Facility’s covered process and...

Respondent is the owner and/or operator of a manufacturing facility, where vinyl fluoride is a raw material used at the Facility during the polymerization process, which is a risk management program covered process. The equipment in the polymerization process includes a supply tank, a reactor, separators, and a slurry flash tank. At the slurry flash tank, steam and vinyl fluoride are flashed off through...

OSHA’s new Confined Space standard for Construction requires a “competent person” in two CRITICAL functions; I should also point out these two functions are also CRITICAL within the General Industry functions as well.  These include EVALUATING spaces and RECLASSIFYING a PRCS to a non-PRCS. Evaluation of Spaces 1926.1203(a) Before it begins work at a worksite, each employer must...

This week OSHA issued a PPE citations to a glass manufacturing company after a worker suffered third-degree burns on his legs and hands when molten glass bottles fell on the production floor and ignited oil residue that had leaked from the machines.  The proposed fine for ONLY the PPE citations involving FRC concerns was $85,000.  TAKE NOTICE… … HomeRead More »

And it has begun… With OSHA’s new Confined Space construction standard, they stated in 1926.1203(a) that… Before it begins work at a worksite, each employer must ensure that a competent person identifies all confined spaces in which one or more of the employees it directs may work, and identifies each space that is a permit space, through consideration and evaluation of the elements...

For those of you at PSM/RMP covered facilities, this OSHA standard is a baseline requirement; however, this OSHA standard does NOT require a Hotwork permit.  It merely “prefers” the authorization be “in the form of a written permit”.  It was not until OSHA’s Process Safety Standard (and EPA’s RMP) that OSHA/EPA actually REQUIRE a hotwork permit be issued...