As a part of the hazard assessment requirements in 40 CFR Part 68, Subpart B, I must analyze worst-case release scenarios and document certain analyses in my risk management plan (RMP). How many worst-case release scenarios must be analyzed, and how many analyses must be specifically documented in the RMP? … HomeRead More »

How do the Clean Air Act (CAA) risk management program requirements differ from the hazardous chemical reporting requirements under the Emergency Planning and Community Right-to-Know Act (EPCRA)? … HomeRead More »

Recently, I had the pleasure of touring the flagship facility of one of my original supporters of SAFTENG. The safety pro is a world-class leader and a fine safety engineer. When he arrived at this facility, he and the PM decided to rid the workplace of all the “safety banners.” Most had become eye-sores, some so badly damaged they were not even legible (but still hanging by a thread). My role during...

Which establishments are covered by the update to the HCS? The scope and framework of the HCS have not changed with this rulemaking. Chemical manufacturers and importers are still responsible for providing information about the hazards of chemicals they produce or import. All employers with hazardous chemicals in their workplaces continue to be required to have a hazard communication program and to...

#1 If an employee presents a work status that indicates they are able to perform restricted work or light duty work yet we do not have work available that meets the restrictions, should we enter the number of days under “On Job Transfer or Restriction” or “Away from Work?” … HomeRead More »

Respondent operates a facility that produces glass-to-metal seals and high-temperature co-fired ceramics for use in semiconductor products. The Facility is located just over half a mile from a residential neighborhood; just under three-quarters of a mile from a charter school; just over three-quarters of a mile from a church and a skating rink; less than one mile from an elementary school and a fire...

I am just getting into Carsten Busch’s book The Heinrich Project III and it has already made it onto my top 10 list for safety pros. Carsten put together all of H.W. Heinrich’s articles and speeches from when he was with Traveler’s Insurance. If you are a believer, as I am, in many of the traditional OSH approaches to preventing accidents, you will be amazed at Heinrich’s ability to be the safety pioneer...

There has been a lot of public debate about OSHA’s attempt to update its emergency response standards.  And in this debate there has been a lot of misinformation shared across municipal and private fire brigade groups in what OSHA is actually trying to implement.  This document, from OSHA, is a compilation of the questions posed and issues raised in the Notice of Proposed Rulemaking...

Respondent operates a facility to manufacture chlorine, bleach, and hydrochloric acid. At all times relevant to this CAFO, Respondent produced, used, or stored more than 2,500 pounds of chlorine at the Facility and was subject to the requirements of CAA § 112(r)(7). At all times relevant to this CAFO, Respondent produced, used, or stored hydrogen at the Facility and was subject to the requirements...

Recently, I had the pleasure of working with one of my international clients at several locations.  This is in thanks to Paul A. for putting his trust in me throughout my career.  Paul and I met in Omaha, NE, in the late 90s and formed a professional and personal friendship as he is ALL ABOUT SAFETY guiding business decisions.  We worked for a man I have mentioned numerous times, Dale...

Much of my work involves helping clients achieve more than “compliance” with minimum government standards.  I typically do this using RAGAGEPs; however, those may be too much to handle in some situations.  So, I will propose another government standard that applies to the process/hazard.  For example, unloading flammable liquid railcars.  Canada has some of the most...

This is safety satire on a Friday afternoon after a long week! I may not be a Certified Welding Inspector (CWI) or a Visual Level II inspector certified per ASME V Supplemental NDE Certification requirements. Still, I believe API 570, Section 8 Repairs, Alterations, and Rerating of Piping Systems allows only a dozen or fewer radiator hose clamps in repair specifications.  I may be slightly off,...