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Can my PSM covered process be a RMP Program 1 process?
Absolutely it can, and allow me to explain how.  We start our Risk Management Plan (RMP) program(s) level assessment with Program 1, then if our process(s) does not qualify for Program 1 we ask ourselves if our process(s) would be a Program 3, and then if the process does NOT qualify for Program 1 or 3, then our process(s) will fall into Program 2 by default.  So we look at Program...
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Buyer beware of who you listen to when it comes to safety advice
I take pride in the fact that me and my team will tell clients WHAT THEY NEED TO HEAR rather than what they would like to hear. We are all about making sure their workers and business have the most safe work place possible. The vast majority appreciate this and it’s why SAFTENG has thrived all these years. But it really pisses me off when my smaller clients contact me with some sales pitch from...
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2016 Video of the Week #37 (Forklift Fatality)
WARNING!  Viewer Discretion advised.  No blood or gore, but it is an accident caught on camera and may be upsetting to some viewers. 1910.178(n)(4) The driver shall be required to slow down and sound the horn at cross aisles and other locations where vision is obstructed. If the load being carried obstructs forward view, the driver shall be required to travel with the load trailing...
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NIOSH Study Supports the OSHA Annual Fit Testing Requirements for Filtering Facepiece Respirators
Results of a recently completed 2015 NIOSH study confirm the necessity of the current Occupational Safety and Health Administration (OSHA) respirator fit testing requirement, both annually and when physical changes have occurred. The study’s conclusions emphasize that respirator users who have lost more than 20 pounds should be re-tested to be sure that the current size and model of respirator...
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Do I have to count the quantities of my RMP covered chemicals in railcars sitting on my site?
We don’t see this often, so I feel it is worthy of posting this RMP Citation.  I have written several articles about this and posted a couple of citations.  This one was just posted this week… Process Safety Information [40 C.F.R. 68 .65(c)(l)(iii)] – $300 [Facility] failed to include quantities containing regulated substances purchased for its facility located...
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OSHA's investigation of lathe operator's fatal injuries finds machine guards were bypassed at machining facility
A few weeks back I posted a OSHRC decision where an OSHA citation for not treating the CNC doors as guards was upheld.  Since then I have received numerous e-mails and a few phone calls telling me I am crazy, as if it was my decision.  Then last week the Video of the Week was a series of video’s showing failures within a CNC machine and how a closed door would have helped protect the...
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General Industry vs. Construction on Permit-Required Confined Space Citations (OSHRC)
The company specializes in the cleaning of gasoline and gasoline tanks for gasoline retailers. On December 30 and 31, 2014, OSHA’s Compliance Officer (CSHO) conducted an inspection following a fatal accident at that worksite. An employee died after being found unresponsive at the bottom of a well containing a submersible turbine pump (STP) at a retail store under construction. Based upon the...
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Excellent Video demonstrating the behaviors of hazardous materials
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I07LiIc
2016 Photo of the Week #36 (Grinding is "hot work"... as he is about to find out!)
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2016 Video of the Week #36 (Explaining the Engulfment Hazard)
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LadSaf Sleeves
DBI-SALA® LAD-SAF™ SLEEVE – STOP USE AND VOLUNTARY RECALL / REPLACEMENT
After more than 30 years of use in the fall protection industry, the original Lad-Saf™ sleeve has been replaced by a completely redesigned next generation Lad-Saf sleeve.  Capital Safety/3M recently reviewed the performance of the original Lad-Saf sleeve in the field, including a limited number of incidents involving a serious injury or death in the United States while using the...
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Dr. James Reason's 12 Principles of Error Management
Dr. Reason is recognized as a world-leading expert on human error, with a distinguished career spanning industry, healthcare, and academia. He is a graduate of the University of Manchester and held the position of Professor of Psychology from 1977 to 2001.  Professor Reason is probably best known for his “Swiss Cheese” Accident Causation Model which he published in 1990. While attending...
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