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April 13, 2011
OSHA has a long and consistent history of interpreting its standards and other requirements to require employers to present information in a manner that their employees can understand. See, e.g., CPL 2-2.38(D)(1998) (“[i]f the employees receive job instructions in a language other than English, then training and information to be conveyed under the [hazard communication standard] will also need...
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April 13, 2011
Paragraph (c) of 29 CFR 1910.151 requires that suitable facilities for quick drenching or flushing be provided within the work area for immediate use if an employee’s eyes or body may be exposed to corrosive materials. The OSHA standard does not set specifications for emergency eyewash and shower equipment, but we agree that equipment that complies with ANSI requirements would usually meet the...
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April 13, 2011
MultiVapor is a computer tool for estimating breakthrough times and service lives of air-purifying respirator cartridges manufactured to remove toxic organic vapors from breathed air. It can also be used for larger filters and for carbon beds of any size prepared for laboratory studies. MultiVapor replaces the program, Breakthrough, which performs the same function for only one organic vapor at all...
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April 11, 2011
If you have ever walked the stairs of a highrise building or the halls of a large hotel you have seen a “Standpipe System”. Many industrial facilities have these systems in place as well. In fact some state fire and building codes REQUIRE these systems be “installed”. Notice I emphasised “installed”, as most were installed, but have not been maintained,...
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April 11, 2011
One of EPA’s most often cited issues with a facilities Risk Management Plan (RMP) revolves around “updates to the plan”. Most, but not all, know that the plan has to be updated every five years; but did you know there were other triggers that require a RMP to be updated more often than every five years. Here are the changes that would REQUIRE an UPDATE to an RMP: …...
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April 11, 2011
Does your facility have a standpipe system? Does the facility test the hoses and nozzles on these systems annually? Does the facility inspect them montly? BEFORE I even say anything, let me say my DISCLAIMER…check with your local fire department(s) AND your property conservation insurer BEFORE you remove the first hose or nozzle! Now that I have said that, you will want to do...
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April 11, 2011
In this article I would like to lay the foundation for future discussions on one of my favorite topics…Flammable Liquids. I will try to explain flammable liquids at their very basic level. There is MUCH MORE to learn about flammable liquids, but this will get us off to a good start with the fundamentals. Let’s start by discussing the term Flash Point. We could say...
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April 10, 2011
We are never quite sure how these myths get started, but my team and I hear some doosee’s from time to time. The “myth” I am going to discuss today is one we actually see more often than not. We see this even in facilities that have a good grasp of their Hazardous Locations and of course we see it most often in facilities that are struggle with classifying thier hazardous...
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April 10, 2011
Most of us know that OSHA requires us to retain our canceled PRCS Entry permits for one year to be able to do our annual review of our program, which is also an OSHA requirement. However, and this is a HUGE “however,”…if the permit’s air monitoring section shows there was any exposure to a contaminant, that permit would fall under 1910.1020 retention requirements (e.g.,...
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April 10, 2011
Anyone who has been involved in incident investigations will just smile and feel a lot of relief that your world is not so different than the safety professional down the street! Although the video is slanted toward a QC type investigation, you will be able to relate to the LAME _ _ _ _ corrective actions in this “Top Ten List of Unacceptable Corrective Actions“. See if you...
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