Although this question has been discussed before, OSHA issued a new Letter of Interpretation (LOI) late in 2023 (posted in 2024), answering the following question and has ARCHIVED their previous LOI from November 26, 1996. Does OSHA consider the initial monitoring data and subsequent re-testing data to constitute employee exposure records subject to the record retention period in 29 CFR § 1910.1020(d)(1)(ii)?...

OSHA has posted a Letter of Interpretation (LOI) regarding  “industrial markers containing liquid paint or ink. ” Here are the four (4) questions OSHA answers: Question 1: Can an industrial isopropyl alcohol (IPA) or ethyl acetate (EA) based marker containing 10 milliliters (ml) of liquid paint or ink be considered an article per paragraph 1910.1200(c) of HCS 2012? Given the [minute]...

One of our “Partners in Safety”, The Chlorine Institute (CI), has published a new resource for first responders on safely handling “orphaned” chlorine containers. CI defines an “orphaned” chlorine container as a chlorine cylinder or ton container that has been abandoned and is effectively without an owner. CI developed this new orphaned chlorine container guidance to aid first responders...

As I continue my efforts to educate the safety profession in process safety and, more specifically, on the differences between welded pipe joints versus flanged pipe joints, this topic usually comes up.  The big question that is the 800-pound gorilla in the room is… If both welded and flanged joints are allowed in our flammable liquid processes, then why does NFPA 497 only make an exception...

This week, I am doing my intermediate 3-day process safety training course for a new client whose process HHC/EHS is Liquefied Petroleum Gas (LPG); however, this process is VERY different than the other clients I have whose HHC/EHS is LPG.  My clients are END-USERS of LPG; this facility is NOT the user of the LPG; they merely process it and store it for distribution to the END-USER.  They...

Respondent owns and operates a metal parts heat treatment operation and maintains a maximum inventory of 60,000 pounds of anhydrous ammonia, at the Facility, which exceeds the threshold quantity of 10,000 pounds. Respondent uses anhydrous ammonia in its heat treatment process. EPA inspectors completed an announced CAA 112(r) inspection on June 15 through June 16, 2022 (June 2022 Inspection). Respondent...

Respondent is supplied with raw chemical feedstocks by tanker truck or railcar. Chemical unloading operations occur on the eastern portion of the Facility at dedicated tank truck and railcar unloading stations. Several chemicals are stored in bulk at the Facility in dedicated aboveground storage tanks (ASTs), including, nitric acid (one tank), hydrogen peroxide (four tanks), sodium hypochlorite (two...

Respondent operates a granular monoammonium phosphate (GMAP) process and a diammonium phosphate (DAP) process at the Facility, meeting the definition of “process” as defined by 40 C.F.R. § 68.3. A different Respondent operates an anhydrous ammonia process at the Facility, meeting the definition of “process” as defined by 40 C.F.R. § 68.3. The GMAP and DAP processes are located on contiguous property...

I am teaching my 3-Day Intermediate Process Safety course this week, and one of the popular exercises we do on Day 1 is the “Vehicle Safety Challenge.”  It is designed to teach students to begin thinking about Layers of Protection within the PREVENT-PROTECT-MITIGATE model.  Five students in four (4) groups have 15 minutes to … HomeRead More »

The good old “safety incentive program” has been around since man walked upright and has been misleading management since its conception.  The concept is valid, based on the old “carrot and the stick” model.  There has always been one fatal flaw in these programs… they usually incentivize the WRONG things!  The traditional safety incentive programs, many...

One of the top questions we get regarding contractor safety is, “Do I have to evaluate, orientate, and audit subcontractors working for a contractor we hired?”.  OSHA’s latest revision of their PSM CPL answered this question. Is the host employer of a PSM-covered facility responsible for the safety of subcontractors? … HomeRead More »

The NSW Resources Regulator has published a fact sheet on its human and organizational factors data review.  The Regulator engaged the Keil Centre to independently review its human and organizational factors analyses over the past five (5) years, where HUMAN ERROR and DELIBERATE NON-COMPLIANCE played a role in incidents.  The review looked at 267 incidents at 180 at surface mines and 87 at...