First, I am not fully bought into the “psychological safety” concept.  For me, it is just how we should manage safety, so I am not a “labels” kind of safety pro.  However, I get a lot of questions about HOP and Psychological Safety, and the one place we could begin to utilize these approaches is in our “annual periodic LOTO inspections.”  Let me explain…...

On New Year’s Eve, I hope many safety pros will choose a 2024 resolution to end the regurgitation of OSHA standards as their “written programs.” I have always used the OSHA standard as my baseline, but these programs need to EXPLAIN HOW the facility will meet the requirements – not repeat the requirements. For example… I hope we can move on from simply cutting and pasting...

One thing that many find confusing regarding the control of hazardous energy is the actual hazard they are trying to render to a Zero Energy State (ZES).  This is a simple concept, but many get it wrong in their programs and machine-specific procedures.  Let’s take compressed air as an example.  Many compressed air systems in manufacturing facilities will operate around 120 psi. ...

What happened? The extinguisher, rated to 2900 psi was being tested to a pressure of 4351 psi. The incident occurred when the test pressure reached 2842 psi. The extinguisher was 13 years old. No one was harmed. The failure occurred under test conditions, and no personnel were nearby to be injured. The hydrostatic test was a scheduled 5-year test carried out as per the company’s planned...

NOTE: this was NOT a PSM covered process. OSHA determined the employee — on the job just two months — opened an air intake valve to inspect a noise coming from a barium sulfide wash cone with a steam line that was left open the day before. A rush of cold air in the steam line created a bubble that pushed up heated sludge onto the worker, causing fatal burns. A second worker suffered second-degree burns...

WAC 296-880-20005 Fall protection required at four feet or more … … HomeRead More »

Lockout is a life-critical program/process/procedure(s). Our efforts to VERIFY that the program/process/procedures meet our needs is a CRITICAL path in the LOTO process.  OSHA recognized this when it promulgated its Control of Hazardous Energy standard (1910.147).  Specifically, 1910.147(c)(6) “Periodic Inspections” requires the employer to verify the program/procedures and that...

High-hazard Group H occupancies are characterized by an unusually high degree of explosion, fire, or health hazard compared to typical commercial and industrial uses.  There is one common feature about Group H occupancies—they are designated as Group H based on excessive quantities of hazardous materials within the facility/building. Where the quantities of hazardous material stored or used in...

From “facility siting” in a PHA to establishing emergency “assemble areas,” the methodology we use matters.  Many of us use a RAGAGEP from The European Industrial Gases Association (EIGA) titled Methodology for Determination of Safety and Separation Distances.  The “safety distance” is to provide a minimum separation that will mitigate the effect of any...

Today the U.S. Chemical Safety and Hazard Investigation Board (CSB) released its final report on a flammable vapor explosion and fire at the Yenkin-Majestic facility in Columbus, OH, on April 8, 2021. One employee died during the incident, and eight other workers were injured. The CSB’s final report makes several important safety recommendations to Yenkin-Majestics, as well as to professional...

Recently, OSHA cited a global manufacturer for HAZLOC violations using its 1910.307 – Hazardous (classified) locations standard.  We do not see this standard often cited, as in most PSM/RMP citations related to Hazardous Locations (HAZLOC), OSHA and EPA will reference the RAGAGEP NFPA 70.  It is one of our common findings in our PSM/RMP audits at flammable processes; however, our findings...