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...

Should employees evacuate or be prepared to fight a small fire? … HomeRead More »

A lot of PSM/RMP covered processes utilize ventialtion as an engineering control within the process.  And if this is the case, then OSHA and EPA require the facility to have supporting documentation to show that the ventilation will do what it it intended to do. … HomeRead More »

Some companies develop an elaborate generic energy control procedure and supplement the generic procedure with checklists or appendices to address various distinct machinery and equipment in their facilities. This type of procedure and those described above may be considered a single energy control procedure (instead of multiple procedures) for inspection purposes if all of the criteria contained in...

OSHA says we are to have machine-specific LOTO procedures (note that there is an exception to this requirement, but in my scenario, it is not relative). In these procedures, we have to identify the following: the types of energy, their magnitudes, the means/methods to isolate and the means/methods to verify zero energy state (ZES) for each source Suppose you or I go out to do our periodic LOTO inspection,...

No hunman and no organization is perfect!  Although we should strive for perfection in all aspects of business (Production, Quality, Cost Control, and EHS), we often mis-step or possible loose our way altogether.  But how bad do things have to get before it is a REAL PROBLEM? … HomeRead More »