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I am proud to announce that SAFTENG and The Chlorine Institute have renewed our partnership for another year (through 2026).  Members of The Chlorine Institute receive a FREE SAFTENG membership.  If you qualify, please contact me

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2017 Video of the Week #13 (Confined Space Explosion in Gasoline Tank - CCTV)
VIEWER DISCRETION ADVISED!
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FPP EAP Flow Chart
Am I required to have a Fire Prevention Plan (FPP)? (1910.39)
Much like the Emergency Action Plan (EAP) requirements, a WRITTEN FPP is ONLY required when your business/facility falls under some other OSHA standard.  And in the case of FPPs, there are ONLY three (3) OSHA standards requiring a FPP: Ethylene Oxide, 1910.1047 Methylenedianiline – 1910.1050 1,3-Butadiene – 1910.1051 Here is a nice flowchart from OSHA on making your decision: …...
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Isolating a Permit-Required Confined Space (1910.146(d)(3)(iii)
So what exactly does OSHA mean when they say… Develop and implement the means, procedures, and practices necessary for safe permit space entry operations, including, but not limited to, the following:…1910.146(d)(3)(iii) Isolating the permit space It is not uncommon to find spaces entered with NO isolation of the space and there tends to still be some “behind scene” arguements/debates...
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OSHA's take on Atmospheric Hazards inside Permit-Required Confined Spaces
Back when OSHA was writing their Permit-Required Confined Space standard (1910.146) their review of accident data indicated that most confined space deaths and injuries were caused by atmospheric hazards.  And yet, still today, we see entrant, attendants, and entry supervisors; and even safety personnel, not understanding the atmospheric hazards associated with PRCSs.  I hope to shed some...
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OSHA issues PSM Citations @ meat processor (NH3 & $75K)
Violation Summary   Serious Willful Repeat Other Unclass Total Initial Violations 15         15 Current Violations 15         15 Initial Penalty $128,562         $128,562 Current Penalty $75,000         $75,000   Violation Items # ID Type Standard Curr$ Init$ LastEvent 1. 01001 Serious 1910.119(d)Process...
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Why does OSHA consider a "blank flange" and "bolted slip blind" as a Lockout device?
In OSHA’s LOTO standard (1910.147), the agency included in their definition of a “lockout device” a “blank flange” and “bolted slip blind” when in fact, these devices are actually “energy isolation devices.”  So why would OSHA consider these devices a “lockout device”? NOTE:  I am not in agreement with this and have never called a...
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When is an "energy isolation device" "capable of being locked out"
In the Final Rule, OSHA determined that lockout is a surer means of ensuring equipment is de-energized than tagout and is the preferred method. However, the Agency also recognized that tagout will nonetheless need to be used instead of lockout where the energy control device cannot accept a locking device. Where an energy control device has been designed to be “lockable”, the standard REQUIRES...
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Enforcement of minimum approach distance requirements in 29 CFR 1910.269 and 29 CFR Part 1926, Subpart V
On April 11, 2014, OSHA promulgated a final rule revising the general industry and construction standards for work on electric power generation, transmission and distribution installations. On February 13, 2015, OSHA entered into a settlement agreement with the Edison Electric Institute, the Utility Line Clearance Coalition, and the Tree Care Industry Association resolving legal challenges to that...
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OSHA clarifies the NRTL listing/approval requirements for non-electrical vacuum cleaners used in combustible dust atmospheres (OSHA LOI)
Scenario: Some equipment manufacturers believe that all equipment used in combustible dust atmospheres, including non-electrically powered vacuum cleaners, requires NRTL listing/approval. Question: Could OSHA clarify the NRTL listing/approval requirements for non-electrical vacuum cleaners used in combustible dust atmospheres? … HomeRead More »
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2017 Video of the Week XXXX (an inside view of what an inadequate sprinkler system looks like)
This is helmet camera footage from one of the first firefighters to arrive at one of 2015’s largest loss fires in the USA.  $110,000,000 loss dues to an inadequate sprinkler system due to changes in occupancy over the years!  
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Process Safety Management Course - Advanced (4/3-4/7/2017)
I have been given permission to OPEN up a PSM Training course in April to other clients/members.  This is a 4.5 day training course and involves field-work, so you will need to bring your PPE (Safety Glasses, Safety Boots, Hard-Hat, and FRC if you have it).  The course will be taught with a focus on Category 1 FLAMMABLE HHC, but this is such a detailed course we learn principles and...
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1/4" openings are NOT universally permissible on machinery (OSHRC Machine Guarding decision)
This case is yet another example of how “legal” and “safety” can be so far apart from each other.  This case was won by the company because OSHA did a horrible job in defending their citation; and yet, it will become ammo for companies to use in future cases.  Let’s not fool ourselves into believing that a 1/4″ opening around a conveyor does not present...
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