So many of us can recall the 2012 “Letter to Regional Admins” titled Employer Safety Incentive and Disincentive Policies and Practices where OSHA called out “safety incentive” programs that encourage under reporting of accidents.  Then it was merely a “letter” to regional admin(s).  Now the Field Operations Manual (FOM) has been revised in a manner...

What’s changed in MARPLOT 5.0.2? … HomeRead More »

This guide is intended to help small businesses comply with the Confined Spaces standard. It addresses the most common compliance issues that employers will face and provides sufficient detail to serve as a useful compliance guide.  It does not, however, describe all provisions of the standard or alter the compliance responsibilities set forth in the standard, which is published at 29 CFR §§...

Comparing RMP Level 2 to Level 3 Programs RMP Program Level 2 RMP Program Level 3 §68.48   Safety information (a) The owner or operator shall compile and maintain the following up-to-date safety information related to the regulated substances, processes, and equipment: (1) Material Safety Data Sheets that meet the requirements of 29 CFR 1910.1200(g); (2) Maximum intended inventory...

This list was released at last week’s National Safety Council‘s 2015 Congress & Expo.  OSHA’s Top 10 for FY 2015 (10/1/2014 through 9/8/2015) are: Fall Protection (1926.501) – 6,721 violations Hazard Communication (1910.1200) – 5,192 Scaffolding (1926.451) – 4,295 Respiratory Protection (1910.134) – 3,305 Lockout/Tagout (1910.147) – 3,002 Powered...

Lets walk through a process in which we will isolate a PRCS using either the blinding/blanking or disconnect and misalignment provisions.  The vessel we will enter is a PSM/RMP covered piece of equipment.  Here’s how I was taught the process works… Since this is a PSM/RMP covered process we will be impacted by three key OSHA standards: 1910.147 – The control of hazardous energy (lockout/tagout)...

UPDATED 10/5/15, see bottom of page Another common debate we like to have among our profession… When is entry rescue required, and when is non-entry rescue required for entries into Permit-Required Confined Spaces?  Ask ten safety professionals who are really into PRCS safety, and I will bet you a burger and a beer that we will not get 100% agreement.  1910.146 language does not make this...

How many Confined Spaces do you see? How many Confined Spaces signs would you use? PLEASE note that without knowing the hazards of these Confined Spaces, I chose to call them only Confined Spaces rather than Permit-Required Confined Spaces.  CS’s are NOT required to be labeled, but PRCSs are REQUIRED to be labeled, except under certain circumstances, which must be managed very carefully....

EPA conducted an inspection of the Facility on December 4, 2012. The Inspection was conducted to determine the Facility’s compliance with Sections 112(r)(7) and 112(r)(1) of the CAA, the RMP accident prevention program and the General Duty Clause, respectively.  At the time of the Inspection, Respondent had designated the Facility as an RMP Program Level 3 facility.  Respondent stored...

OSHA is REVISING the electrical safety-related work practices standard for general industry and the electric power generation, transmission, and distribution standards for general industry and construction to provide additional clarification regarding the applicability of the standards to certain operations, including some tree trimming work that is performed near (but that is not on or directly associated...

As we are now 20+ years into the PSM standard (16 years for RMP) I think it may be time to revisit the reason for these standards and what OSHA and EPA are trying to drive us to achieve and how our HHC/EHS inventory management plays a HUGE role in this effort.  This MII requirement has not received a lot of attention from OSHA or EPA so there is NOT a lot of literature for us to refer to, but...