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Facility manufactures over 600 small animal products, including bird food, but not dog and cat food, which are sold in small and large chain pet stores. Fifty to 60 employees work in its 120,000 square foot production facility and warehouse. Part of the facility, measuring 8,000 to 10,000 square feet, is devoted to assembling small animal products from 2500 types of raw materials, including millet...

These LOTO decisions by the OSHRC are HUGE in establishing some “minimums” for LOTO procedures, periodic inspections, and training for “affected” and “other” employees.  Readers should pay very close attention to the details that OSHA used in their arguments of how poorly “machine-specific procedures” were written (missing data, conflicting data,...

Respondent owns and operates a controlled-temperature storage warehouse for food products. The Facility is located adjacent to Interstate 91 and east of the Quinnipiac River, within a mile of numerous shops and business and approximately 1 mile from several schools. Respondent uses anhydrous ammonia in a refrigeration “process”.  In 2009, Respondent filed a Program 3 RMP for the Process...

  2nd Quarter UPDATE with 289 Shocker and Accident Photos Now over 13,750 exclusive unsafe acts/conditions and accident/injuries photos and over 1,000 ppt’s & doc’s from more than 2,776 contributors!   Many THANKS to my RENEWING “Partners in Safety“ since 2009 since 2014 since 2009 since 2009 2014 Fatality Tracker Electrical 50 (2013 = 32) (2012 = 68)...

A very common question we get during our work is… “Am I required to have a first aid team on site?” And “If I am, do they fall under the Blood Borne Pathogen standard”?  OSHA actually provided us some great insight into their position on these questions in a 2007 LOI.  They stated… … HomeRead More »

WOW… you want to read a case from !@#$, this will be some interesting reading for you.  If there was ever a case where the lesson is “Do as you say you’re going to do in your safety program” this case is the “poster child” for that cause.  Too many strikes against the management at the USPS to list so I am just going to provide the link to the case,...

This case makes two (2) decisions that on the surface appear to be a step backwards – but readers should not read anything into these decisions!  The refrigerator in the power strip was lost merely because the CSHO did NOT document the power pull the refrigerator was putting on the power strip.  So before we go thinking that we can plug our refrigerators into power strips SAFELY or...

OSHA/EPA is still issuing Facility Siting citations, just this week there was one issued, for a facility not including an FS analysis as part of their process hazard(s) analysis.  This week’s photo shows the result of common findings from our FS Analyzes. Critical equipment along roadways MUST be protected from vehicle impact – it does not get any SIMPLER than this!  So the next...

Respondent operates water filtration plants which store or otherwise use chlorine in an amount exceeding its applicable thresholds of 2,500 pounds. Respondent has submitted and registered an RMPlan to the EPA for these stationary sources and has developed an RMProgram (accident release prevention program) for these stationary sources. Based on an RMProgram compliance monitoring investigation conducted...

A while back, I was participating in a PHA of a refrigeration process, and somehow, the discussion led to one that scared me a bit… collecting a liquid ammonia sample to test for water content.  The actual art of ammonia refrigeration not being my area of expertise, I had always reserved Bulletin No. 108. Guidelines for Water Contamination in Ammonia Refrigeration Systems for a rainy day...