We hear and see this all the time.  There are variations to this mantra, but we all know what they mean.  So I ask, can a business ever live up to its mantra, “Safety is #1”? Some companies have softened their approach and will say, “The safety of our employees is our #1 priority”.  We usually hear this right in the PR statement after a tragic accident. ...

As I have stated, our Safety Management System (SMS) revolves around four (4) fundamental elements: 1) Hazard Identification 2) Analysing those identified hazards using recognized methodologies 3) Assessing the risk(s) those hazards pose to people, businesses, and the environment 4) Mitigating those risks down to a tolerable level using the Hierarchy of Controls With that said, Hazard ID is our first...

It is well established that in organizations where a formal and structured SMS approach to managing safety failed, the #1 cause of the failure was the lack of leadership and commitment from the most senior management personnel.  Often these individuals lack experience working within a formal SMS structure and have never been taught or even seen how they play a crucial role in the development,...

Notice I used the word “necessary” and not the word required.  In my experience, a PSSR saved my ass plenty of times when OSHA/EPA did NOT require it.  To my knowledge, OSHA (nor EPA) have defined the word “facilities” in the context they used it in 1910.119(i)(1)… (emphasis by me) 1910.119(i)(1) The employer shall perform a pre-startup safety review for NEW...

The U.S. Environmental Protection Agency (EPA) and Justice Department have reached a settlement with a food processing company to resolve alleged violations of the Clean Air Act (CAA) and Emergency Planning and Community Right-to-Know Act (EPCRA) at the company’s food processing facility in North Kingstown, Rhode Island. The alleged violations pertain to chemical release prevention and reporting...

I challenged a product recently on a LinkedIn post. My challenge was based on a video advertisement and caused me to question the product and what it could do to OSHA and IBC codes related to steps/stairs. One of the company reps, Rick Corbin, contacted me and gave me more information, and I stand corrected.   The product is actually genius – one of those “why didn’t I think...

At 11:09 a.m. on December 19, 2022, an HVAC contractor was installing a heating unit when a coworker operating a scissor lift struck a NH3 pipe/valve that caused a release of ammonia. The contractor, 68, was overcome by ammonia and died.  The lift operator was hospitalized for treatment for his exposure to ammonia. … HomeRead More »

One of the audit findings that we believe to be an essential requirement certainly raises many folks’ blood pressure.  We get accused of “piling on” when we write up findings in our OSH and PSM/RMP audits regarding the incorrect testing of a facility’s employee alarm system(s).  And we use OSHA’s requirements, which are actually quite dated, rather than using...

Between May and November 2020, the National Institute for Occupational Safety and Health (NIOSH) issued limited, temporary Public Health Emergency (PHE) approvals for N95 filtering facepiece respirators (FFRs) and powered air-purifying respirators (PAPRs) to address respirator supply shortages during that time. In July 2021, NIOSH published NIOSH CA 2021-1036 to remind PHE approval holders that...

There was some legal advice given today on a social media site regarding documenting our safety training with sign-in sheets, so if OSHA ever asked for records to show an employee was “trained”, the employer would be able to show the sign-in sheet.  The advice even contained the statement: Your safety training in this respect does not need to be long – in theory, it could even...

Today’s MSHA Fatality Report made me wonder how many LOTO programs require the SECONDARY SECUREMENT of large objects, even after the power source that normally moves the equipment has been locked out.  For example, cooling towers and condenser fan blades. I have experienced firsthand a piece of equipment two times involved were very large fan blades, and they caused serious injuries when they...

The heat index is based on the relative humidity.  When this relative humidity is HIGH, it significantly reduces the ability of our sweat to evaporate off our skin.  This sweating and evaporation process is how our bodies are cooled.  Our Heat-Related Illness Prevention Plan’s “action temperature(s)” MUST be based on the HEAT INDEX – not the standard temperature. ...