At approximately 12:00 p.m. on February 24, 2023, an employee, 35, was performing “well site pumping operations” for an oil and gas producer. A coworker had been trying to contact the employee unsuccessfully, so he went to the oil and gas well site where the employee was working to check on him. The coworker found the employee unresponsive in the small 9-foot by 10-foot well shack. The...

One of the worst injury accidents of my career occurred in a PSM/RMP-covered process but involved a non-HHC/EHS.  The chemical was “hot caustic,” a byproduct from the process used in another process’s scrubber.  A sister facility had an incident in which it was discovered that the caustic was too weak. Thus in a process upset, the scrubber failed to perform correctly, leading...

Five (5) workers died after inhaling suspected poisonous gas emanating from a tank at a food factory in Madhya Pradesh’s Morena district. The incident happened in the Sakshi Food Products factory. Gas began emanating from a tank at the factory that makes food products around 11 am, and two (2) workers entered it to investigate. Both workers lost consciousness after they entered the tank and were inside...

We are seeing more and more of this type of set-up, where an auxiliary piece of equipment on an assembly/production line has two (2) electrical supplies.  One is from the main SWITCH on the line, and one is from a separate source.  This is usually done when the auxiliary equipment may need to stay energized during interruptions. An excellent example is a hot glue machine used in packaging...

If we reverse the brake and accelerator pedals on your car, even if you are warned, and a sign reminds you, you can be sure that sooner or later you will press the accelerator when you meant to brake. Source: Human and organizational factors of safety: a state of the art, Daniellou, F., Simard, M. and Boissières, I. (2011)

Most facilities will have a few pieces of equipment that require using a dozen or more energy isolation devices to achieve a full LO’ed situation.  Most businesses, at least early on in their implementation of LOTO for these pieces of equipment, will state ALL energy isolation devices will be utilized regardless of the scope of work being performed.  This may seem like the “safest”...

1101.1 Scope. This chapter shall govern the design, installation, construction, and repair of refrigeration systems. Permanently installed refrigerant storage systems and other components shall be considered as part of the refrigeration system to which they are attached. 1101.1.1 Refrigerants other than ammonia. Refrigeration systems using a refrigerant other than ammonia shall comply with this chapter,...

Have you ever seen a setup on a machine, typically those manufactured outside of the USA, with two (2) electrical disconnects?  Most of the time, these disconnects are COLOR-CODED to clearly identify their different uses, although we have seen some that were NOT color-coded, nor were they properly labeled!  Here is an example of what this may look like; I have highlighted both switches with...

Whenever we talk about OSHA’s Lockout/Tagout (LOTO) standard, we almost always have to talk about its machine guarding and electrical standards.  One crucial requirement in OSHA’s electrical standards, as it relates directly back to LOTO, is … (emphasis by me) … HomeRead More »

In the 20th Century, the great Professor James Reason foresaw how 21st Century Safety Management would have to evolve to move us to the next level. Two (2) approaches to the problem of human fallibility exist: … HomeRead More »

Guidelines for Preparedness and Initial Response to a Pipeline Release of Carbon Dioxide (CO2) This field operations guide is not an educational or decision-making tool. This guide contains a set of operational tools and references to assist in the response to a pipeline release of carbon dioxide (CO2). The priorities for CO2 response are: … HomeRead More »

An inside look at what OSHA proposes in their Heat Injury and Illness Prevention Program (HIIPP).  This is from the Small Business Regulatory Enforcement Fairness Act (SBREFA) panel. This document is meant to outline potential options for the various elements of a proposed rule. OSHA envisions a programmatic standard that could require employers to create a plan to evaluate and control heat hazards...