A few months back I posted an article regarding OR-OSHA’s revisions to their “STATIONARY COMPACTORS, SELF-CONTAINED COMPACTORS AND BALERS” standard and offered up the idea that we could/should be using this state plan standard as our own guidance in how we manage safety around our equipment, even though we are not in the state of Oregon.  They just completed the revisions of...

A few months back I posted an article regarding OR-OSHA’s revisions to their “STATIONARY COMPACTORS, SELF-CONTAINED COMPACTORS AND BALERS” standard and offered up the idea that we could/should be using this state plan standard as our own guidance in how we manage safety around our equipment, even though we are not in the state of Oregon.  They just completed the revisions of...

The new Training Package for responding to ethanol incidents includes an instructors manual, a participant packet, interactive workshop materials, PowerPoint presentations, two videos and guidelines for fire departments to have ethanol production facilities in their communities. This extensive package is very beneficial giving the sources to be knowledgeable and prepared for any ethanol emergency situation....

Chemical-terrorism Vulnerability Information (CVI) is the information protection regime authorized by Section 550 of Public Law 109-295 to protect from inappropriate public disclosure any information developed or submitted pursuant to Section 550. This includes information that is developed and/or submitted to DHS pursuant to the Chemical Facility Anti-Terrorism Standards (CFATS) regulation which implements...

Some may think this is crazy, I do; but I have had many debates with businesses during audits and serious accident investigations around this argument.  There are a lot of mind-sets in plants that have many presses that LOTO does not apply to this task as it would slow production too much and put them out of business.  I am floored each time, as you will see in this analysis, their argument...

UPDATE from my OSHA contacts:  The NEP was written so that OSHA offices would not single out NH3 refrigeration and CL2 water treatment processes.  OSHA feared that since these processes were so plentiful that they would target these types of processes and not inspect other types of processes, so in reality they were spelled out – not to focus on, but rather to prevent OSHA from focusing...

Scenario: An employer requires ordinary safety-toe footwear throughout their facilities and pays for the first $100 of the footwear cost. As part of a recent company-wide static electricity control program, employees working with flammable liquids and products are now required to have static dissipative safety-toe footwear.   Question 1: Would the static dissipative safety-toe footwear be considered...

This NPRM would update the SDO standards referenced in the three paragraphs that comprise the Acetylene Standard. The Compressed Gas Association (CGA) published several editions of these SDO standards after OSHA adopted them in 1974, and one of these standards (i.e., Compressed Gas Association Pamphlet G-1.4-1966), is no longer available for purchase from CGA. Therefore, to ensure that employers have...

There is not a safety professional on this planet that has not had to deal with a worker putting side shields on their street glasses and trying to pass them off as “safety glasses”.  These days we often get the argument from the worker that the lenses are “plastic and are the same as safety glasses”.  Trying to explain the difference between the two can be difficult,...

This table shows the number of RMP facilities — facilities that could potentially have toxic or flammable chemical accidents with off-site consequences. Accident information is summed up from the most recent 5-year accident history for each reported facility. State # of RMP facilities # of accidents # of deaths # of injuries # evacuated Property damage (dollars) Texas 1,392 191 19 781 239,600...

Yes, EPA has a General Duty Clause for RMP, much like OSHA’s General Duty Clause.  However, EPA’s is much more detail.  This month I came across a facility that used to be a RMP/PSM covered facility, but after much work they lowered their quantities below the RMP/PSM Thresholds.  Once this was done, they literally threw away all their RMP/PSM programs (MOC, PSSR, MIP, etc.),...

I have had tons of questions and comments on last week’s article regarding EPA’s General Duty Clause as it relates to RMP Listed chemicals (e.g. Extremely Hazardous Substances) and the requirements for employers, EVEN if they were below the RMP Threshold.  As EPA states in one of their Fact Sheets on the GDC…It is important to understand that the General Duty Clause is not a...