Last month, I discussed what a “management system” would look like should we manage our Permit-Required Confined Space entry operations as a “management system” versus a standalone OSHA compliance program.  (CLICK HERE for that post) Today, I want to discuss the same approach but in respect to how we manage another life safety critical practice… The Control of Hazardous...

A recent story in my local news was regarding changes to traffic patterns made to the 44th most dangerous intersection in OH.  A 2018 traffic study showed there had been 114 crashes at the intersection over the previous four (4) years; 40% of those resulted in an injury.  The state tried just about every administrative control known to man to reduce the number of accidents and their severity. ...

As is evident by several Permit-Required Confined Space incidents over the years, workers MUST FULLY understand the limitations of the respirators they are using.  This latest incident involved a worker who was vacuuming, and the nozzle became stuck inside the tank. To free the nozzle, the worker—wearing a respirator with organic filters used explicitly for working outside the tank—fully entered...

This week, I conducted a 24-hr HAZMAT Tech course for a client.  The facility had purchased some new SCBA cylinders, and we noticed an odd difference between two of the cylinders.  One cylinder was manufactured in 2021, and one was manufactured in early 2022, just six months apart.  As I was covering the requirements for “Emergency Respiraors” to be 90% full BEFORE they can...

This is an interesting “press release” from OSHA.  Although OSHA has a “policy” not to use audits and inspections performed within the facility to issue citations against, when the employer does NOT address the hazards identified in the inspections and audits, OSHA can take issue with this failure to abate.  This is what seems to have happened here.  A complaint...

Unfortunately, this economic image reminds me of some “safety programs” I have come across in my travels… The “program” looks great, sitting on the shelf in the fancy, shiny binder. But once we open the binder/package, we find a lot of “fluff” (i.e., air)! Let’s be serious… Safety is not a marketing or PR exercise of pumping the workforce with fancy slogans and banners around the facility. It...

Why is it that safety metrics always get such a bad wrap? We hear the voices from the back of the room… “what gets measured, gets manipulated,” so the outcry is that somehow measuring safety (other than the regulatory lagging indicators) is a waste of time and misleading. The funny thing is I never hear anyone decrying all the business’s financial metrics, leading or lagging!...

Immediate Action Required Impacted Dates:  October 3, 2023 – December 4 ,2023 3M™ Scott™ Cylinder and Valve Assemblies are safe to use once the instructions in this notice are carried out. 3M Scott have been made aware of a small number of cylinder valves that experienced noticeable rates of leakage upon initial inspection when the valve handwheel was initially opened. This has been investigated...

One of the most recognizable safety devices in the world is a Fire Extinguisher, yet so many know so little about these devices. Let me be upfront with everyone; this article is for those safety pros working with a management team that WANTS to OWN the Safety Process/SMS. The actions I will offer in this article can be taken at any business. Still, without management’s desire to OWN the Safety...

FRA is amending its regulations related to occupational noise exposure in three (3) ways. Special NOTE:  although I agree with this new requirement, it will be virtually impossible for the railroads to comply by March 2024.  There are NOT enough EEBAs in inventory to supply the Class 1s.  Then there is the written program and training that has to be put in place, and one month is impossible...

I see far more damage to atmospheric storage tanks from vacuums than I do from over-pressure events.  In almost every case, the tank had undergone a “change” that created the conditions for a vacuum to occur.  And once we have a pressure differential with a lower pressure inside the tank than the atmospheric outside the tank, the atmosphere will simply collapse the tank.  The...

This image from a UK HSE publication may be the best image I have seen on “process safety” and Basic Process Controls Systems (BPCS). It shows how we PREVENT “overfill” events, also known as a Loss of Primary Containment (LOPC) event in atmospheric storage tanks/vessels. The entire publication is a MUST-read for those who store flammable liquids in bulk ATM tanks. Never mind...