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Active Safety Systems Prevention
How well does management know the "barriers/controls/safeguards"?
When meeting with executive teams, I like to conduct an exercise to gauge the leadership team’s level of knowledge and direct involvement in the safety and health of their employees.  Before getting deep into the organization’s specific barriers/controls/safeguards regarding their top 3 risks (which the team picks), I ask the team to take 10 minutes and identify the barriers/controls/safeguards...
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whose the idiots
Who is the idiot?
We see these silly stickers occasionally in our work with clients. Although they are not official company positions, I am curious as to why they aren’t removed from company machinery and equipment. Could this be because management/supervisors believe this to be an accurate statement/belief? But let’s talk about the message these silly stickers really convey and to do so, I ask the question:...
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The seven C's
The seven C’s of being all we can be as safety professionals.   Compassionate Confident Collaborative Contemplative Civil Curious, and Courageous   Let us remember WHY we became safety professionals AND, more importantly, putting those we have the privilege to protect # 1 in our efforts.   Source: 7 C’s of Compassionate Leaders (Forbes)
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Does staffing impact the culture of safety?
I have grown up in safety and emergency response and found that the tools used in both aspects can cross over to the other.  For example, I use the National Incident Management System (NIMS) Incident Command on accident investigations to bring structure to the team.  In that IC we have a “span of control” of no more than seven (7) people reporting to any one person.  This...
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EPA issues RMP citations @ cheese manufacturing plant (NH3, Line Break Accident, & $38K)
This is an unusual case in that it involved a 20-pound release of NH3 during a “line break” on a refrigeration system.  There was only a single citation and it came at a price of $38,500.  The employee was injured.  I have been unable to locate an OSHA investigation regarding this incident, which occurred in TX.  This case is also interesting in that the company agreed...
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A DECON practice challenge
I have been involved with emergency response for over 30 years. During those years, I trained thousands of municipal and private responders, specializing in traditional Hazardous Materials Responses. During all those years, when I received continuing training from the likes of Texas A&M, LSU, NFA, and SERTC, these advanced courses only validated my first HAZWOPER course at Murray State University...
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Inerting a flammable atm is more of a science than art
Not all “simple asphyxiants” are created equal; thus, not all make for good purging or blanketing.  Would you believe me if I told you that one very common simple asphyxiant gas should NEVER be used for purging or blanketing flammable atmospheres? Many folks view Nitrogen (N2) and Carbon Dioxide (CO2) as very similar.  This is based on how we, as humans, respond to both of these...
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Does OSHA have any specific requirements regarding dimensions of gaps between the moving parts (belt or shaft) and the guards? (LOI)
Yes. OSHA’s standards at 29 CFR § 1910.212 and 29 CFR § 1910.219 apply to the safeguarding of machines and mechanical power-transmission equipment and require guarding to protect the operator and other employees in the area from hazards such as those created by ingoing nip points, rotating parts, flying chips, and sparks. In regard to the gap dimension between belts and their respective guards,...
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Something to think about when preparing to issue discipline to those closest to the risk
I am a proponent of accountability in safety; however, I also believe that accountability is necessary at all levels of the organization.  We tend to be very quick in identifying the ACTIVE failures by those who made the error, mistake, or violation, and a negative consequence was the result (vs. all those times, the outcome was positive).  Heck, in today’s world, we may even have caught...
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What are the final changes in the Safer Communities by Chemical Accident Prevention (SCCAP) Rule?
Some of the more eye-opening revisions: Outlining STOP-WORK procedures in Program 3 employee participation plans A justification in the risk management plan is required when: hazard evaluation recommendations are NOT adopted facility-siting hazard recommendations are NOT adopted Safer Technology Alternatives Analysis (STAA) recommendations are NOT adopted third-party compliance audit recommendations...
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2024 DOT ERG is coming!
DOT/PHMSA have compiled the most important changes from ERG2020 to ERG2024, organized by the color of the corresponding section in the guidebook White Yellow/Blue Orange, and Green In addition to the changes listed below, all sections have undergone minor editorial changes for accuracy and consistency. In this edition, DOT/PHMSA has added QR codes to the back cover of the hard copy version of...
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What does an SMS do for your resources
What does a formal SMS do for me?
One of the top questions I get from “cold callers” or those who have joined SAFTENG and have digested my 400+ articles on Safety Management Systems and all their elements is: So, what does an SMS do for me and my facility? The best way to explain this is by an old scatter chart I had done in 1995 by a consulting firm we hired to help us achieve OSHA’s VPP STAR level of safety. ...
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