We always get the answer…”We do not have any temporary operations,” so that does not apply to us. A good auditor will educate the site personnel by taking them out to the field and finding a bypass around a control device. Then, we will ask for the “procedure” that is used when the bypass is open and the control device is “temporarily” out of service. If you...

Often we see facilities viewing MOC and PSSR’s management systems as DUPLICATIVE efforts. There is a distinct difference between these two PSM/RMP requirements. Basically, this is how it was so explained to me by Russ Evanston, one of the founding fathers of PSM. … HomeRead More »

OSHA and EPA are now citing for not doing MOCs on personnel changes!  The debate rages on for those living in the PSM/RMP world. Just this week, a client called me to help them with an audit finding they received in a third-party audit. The auditor wrote the finding that they were not considering personnel changes in their MOC program. I too often write a similar finding when I come across situations...

Well I told you last week that I would scare the !@#$ out of a lot of you, so here it goes.  Nitrogen can be your ignition source if it is NOT applied and used properly. … HomeRead More »

I have always said that 90% of establishing a safety culture is communication of safety ideas and information.  Safety is competing for the minds of all workers to THINK about SAFETY in all that they do.  We are competing with Quality, Production, Costs Control, Family, etc. in the thoughts of our workers.  A lot of marketing companies have made a ton of $ on selling posters and banners...

There is a lot of confusion on reclassifying Permit-Required Confined Spaces to Non-Permit Spaces, which is allowed on spaces with NO KNOWN or POTENTIAL hazardous atmospheres. 1910.146(c)(7) covers this practice. The key DIFFERENCE between “reclassifying” a space using section (c)(7) and using “alternative entry methods,” which is covered under section (c)(5) is ELIMINATION...

Many THANKS to my NEW & RENEWING Corporate Partners in Safety! since 2007 since 2011 since 2009 since 2/11 2011 Fatality Tracker Electrical 6 (2010 = 90) (2009 = 100) Forklift/Manlift Mobile Equipment  27 (2010 = 110) (2009=88) Mining 43 (2010 = 480) (2009 = 586) Explosions 48 (2010 = 246) (2009 = 302) Cranes 6 (2010 = 50) (2009 = 82) Falls 23 (2010 = 139) (2009 = 172) (2008 = 250) Work Zone...

“Never saddle a dead horse” means that when using your Crosby clips, the “U Bolt” is ALWAYS over the DEAD part of the cable and NEVER on the part of the cable that will see the load applied to it.  In other words, NEVER have the u-bolt over the load side of the cable. Here is a diagram and instructions from Crosby’s website showing the proper use of their clips. …...

“Recognized And Generally Accepted Good Engineering Practice” (RAGAGEP) – are engineering, operation, or maintenance activities based on established codes, standards, published technical reports or recommended practices (RP) or a similar document. RAGAGEPs detail generally approved ways to perform specific engineering, inspection or mechanical integrity activities, such as fabricating a...

I am often asked why I do these publications and how did they get started.  Here is the history and reasoning behind the alerts.  The year was 1993.  Recent graduate and ready to save the world, my first job was at a ink resin plant in SW Louisiana.  PSM was red hot as it had just come out the year before.  What a great time to be getting into the safety field.  PSM really...

At a minimum, the plan must include but is not limited to the following elements [29 CFR 1910.38(c)]: Means of reporting fires and other emergencies Evacuation procedures and emergency escape route assignments Procedures to be followed by employees who remain to operate critical plant operations before they evacuate Procedures to account for all employees after an emergency evacuation has been completed...

In most circumstances, immediate evacuation is the best policy, especially if professional firefighting services are available to respond quickly. There may be situations where employee firefighting is warranted to give other workers time to escape or to prevent danger to others by the spread of a fire. In this case, you as the employer are still required to have an EAP. To help you decide whether...