OSHA answers the following questions regarding maintenance and servicing tasks where Cathodic Protection (CP) rectifiers protect pipes against corrosion. Question 1: Is LOTO of a CP rectifier required when working on a pipeline? Question 2: Is the use of a metallic bonding cable an acceptable practice in lieu of CP rectifier lockout/tagout? Background: Cathodic Protection (CP) rectifiers protect pipes...

Nowadays, most machines/equipment come equipped with a digital HMI screen(s) rather than the old-fashioned “Start/Stop” buttons.  Most see this as an improvement in using technology.  However, for those with “machine specific” LOTO procedures, these HMI screens pose a challenge regarding “verifying ZES” for the electrical energy sources.  In the old...

“Kick Up The Arse” – KUTA principle Here is the rule Comply with the rule Enforce the rule Punish people who don’t comply Put a cop on every beat and police the rule We’ll catch you and watch out. Results? No ownership, limited maturity, and reporting goes “underground.” This thinking drives a “nanny” mindset: power operates rather than influence, people don’t...

OSHA has issued a 2022 LOI discussing the use of Transmitting bulk shipment labels by technological or other means.  In the letter, OSHA addresses the use of QR Codes, which has become a very popular means of conveying information to employees.  Here are the two (2) questions OSHA addresses in its letter: Question 1: Does OSHA have guidance on acceptable methods to transmit labels by “technological...

As we have discussed, the “note and exception” that goes with 1910.147(c)(4)(i) is what I call “simple lockout”; however, I have always stated it was intended for simple electrical lockouts, seeing how one of the hurdles to using the exception was that there could be no “stored energy.”  So, when we look at the eight (8) criteria that must be met in order to...

We can change people’s performance by better training and instructions, better supervision, and, to some extent, better motivation. … HomeRead More »

The leaders of an organization MUST be the drivers of the proverbial “safety vehicle.” They steer and control the acceleration and braking. They also choose where they want the organization to go and enter that info into the vehicle’s GPS. … HomeRead More »

Having a functional and mature Safety Management System (SMS) is ALL about decision-making. Thus, the SMS must be a safety decision-making tool, unlike the traditional safety “programs” that are usually separate from business and operational decision-making.

The appreciation that a person makes of the situation depends mainly on the following four (4) elements: … HomeRead More »

There is NO exception in either 1910.146 or 1926.1201-.1213 for NOT having a rescue plan for “permitted entries” into a PRCS. There is an exception for the “Non-Entry rescue method,” BUT there is NOT one for having a rescue service readily available when the space being entered is a PRCS and the entry method is via an “entry permit” (i.e., Sections (d)-(k) So, the...

On October 9, 2023, at about 11:30 a.m., three (3) technicians tasked with performing maintenance work in an underground fuel reservoir died after they entered the underground tank.  All three died from suffocation.  This tragic incident is like the many before!  A single entrant entered the space and became incapacitated, leading his/her co-workers to go in to help them, only to succumb...

 I had the pleasure of teaching another Advanced Course on Process Safety (40-hr). When discussing Relief Systems, their design, and their RAGAGEP(s), the UPWARDS and UNOBSTRUCTED piece got many questions. ALL RAGAGEPs regarding PRDs will state “UPWARDS and UNOBSTRUCTED” or similar language. Even the older OSHA standards uses the phrase “Upward and Unobstructed” in the...