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Filling buckets with gasoline Highlands County Sheriffs Office
If glass, plastic or other non-conductive container with a capacity of 5 gallons or more is used to transfer a flammable liquid
A common question we get regarding flammable liquids is: Do we have to ground and bond non-conductive containers smaller than 5 gallons?   The proper question should be… what do we need to do to SAFELY transfer flammable liquids into non-conductive containers that are 5 gallons and smaller?   The British Columbian Worker’s Compensation Board standard says it best and offers us...
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PHMSA asking for feedback on "requiring water be the fluid for Hydro testing containers"
The battle continues, this time outside process safety!  I get these arguments routinely when people inquire if they can use their HHC/EHS as the media for pressure and leak testing.  I can only assume that PHMSA is getting pushback by requiring water or other similar viscosity liquid to be used as the test medium. When hydrostatic pressure tests for cargo tanks are required in part 180,...
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Pressure Testing GONE BAD (Fire Protection System)
A worker, 41, sustained a serious head injury and died during a piping pressure test. A pipe had been pressurized for testing, and during the pressure release process, a plate from the pipe system broke free and hit the worker in the head. The MI-OSHA case file is still open.
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Pressure Testing GONE BAD (8" Pipe Failure)
Four employees were testing an 8″ chiller pipe with pressure when a piping joint failed and an employee was struck in the shoulder and head by a valve cap. The employee was transported by ambulance to a Hospital. … HomeRead More »
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PRCS fatality - welding in ship under construction (oxygen-deficiency during welding)
On August 28, 2023, at 7:30 a.m., a worker was welding in a confined space on a ship under construction. The victim was found unresponsive inside of the confined space. Per the medical examiner’s report, the employee was killed as a result of suffocation in an oxygen-deficient environment. NOTE: this is likely due to a shielding gas such as Argon being used in this welding. Source: https://w...
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Cylinders carts OSHA
OSHA addresses Compressed Gas cylinders on carts (OSHA LOI)
Your letter discusses concerns with the safety of compressed gas cylinders on some types of portable carts configured for “in use” or “connected for use.” Specifically, you mention that cylinders, which are top heavy and therefore can be unstable (unbalanced), are commonly found poorly secured to the cart and leave the cylinders susceptible to toppling over when used, moved, or stored. In your letter,...
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IR INV RCS CAP TR process
Why a "causal analysis" needs to be thorough (Things may not be as they appear)
After 30+ years of OSHA’s PSM standard (1910.119), we still come across far too many businesses that just do not understand the difference between the “INVESTIGATION” and the “CASUAL ANALYSIS.”  I use this image from my training course(s) to help them differentiate between the two INDIVIDUAL and SEPARATE steps in the Incident Investigation element (1910.119(m)). I...
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Understanding why we have 1910.165(b)(3) (all pun intended)
1910.165(b)(3) The employee alarm shall be distinctive and recognizable as a signal to evacuate the work area or to perform actions designated under the emergency action plan.   After an employee becomes aware of an emergency situation, the next step involves actions to be performed by that employee. Generally, the actions include evacuation or emergency response to mitigate an emergency...
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What we measure and HOW we achieve our safety goals MATTERS!
My Dad had my brother and I set goals in our lives when we turned 16 years old. Financial, Professional, etc. At 16, we were too young to understand any of it, but he got us thinking. By 18, we started to have an idea of what we wanted when we “grew up”. Take for example, a goal such as… “I want to be a millionaire by the age of 50”.   Let’s say I achieved that...
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Safety Fail sign 2
Literally, what it LOOKS like to leave blind luck behind and embrace LEADING INDICATORS
I’m not asking for much, but before I leave this great and honorable profession, I just hope we can GET BACK TO THE FUNDAMENTALS! A great place to start would be to eradicate all these “Worked ____ Days” signs and progress to celebrate what got us those injury-free days. As I have said for decades… Too much reliance on BLIND LUCK is a dangerous thing.  And far too many...
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Did NFPA make "30 seconds" the norm for "relaxation time"?
Did the 2024 edition of NFPA 77, Recommended Practice on Static Electricity establish a norm for “relaxation time”?  In six (6) different sections across five (5) chapters, the recommended practice cites “30 seconds” as a “suitable precaution.” (emphasis by me) … HomeRead More »
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54 Drill Size
Defining and Quantify when Shut Off Valves are necessary/required
  How many of you have thought these two images would ever have a place in Process Safety? I use them as visual aids when teaching some of my RAGAGEP courses, as they place a mental image that most can grasp into the students’ heads and provide them with a valid engineering metric they can use to ensure their HAZMAT bulk containers have adequate safeguards in their basic design. These...
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