As of July 28, 2023, Congress has allowed the statutory authority for the Chemical Facility Anti-Terrorism Standards (CFATS) program (6 CFR Part 27) to expire. Therefore, CISA cannot enforce compliance with the CFATS regulations at this time. Due to this lapse in statutory authority, CISA cannot enforce compliance with the CFATS regulations. Access to the Chemical Security Assessment Tool (CSAT) 2.0...

So much to learn from this video.  OSH practices need to understand the concept of Layers of Protection:  Prevent, Protect, and Mitigate through our Hierarchy of Controls. GUARDING to PREVENT exposure to hazardous energy, NO LOOSE clothes around power transmission devices (even well-guarded devices) to PROTECT workers, E-Stop to MITIGATE the consequences when #1 and 2 fail! We also must begin...

Most of us have some form of “ventilation” used as an “engineering control” in our workplaces. This is sound advice from our friends “across the pond” in the UK… Note: although they are on a different continent and at a different latitude and longitude, airborne contaminants behave the same as in other countries on this planet.   Thorough examination and testing of LEV The purpose...

One common deficiency we encounter in our chlorine (Cl2) work is the management of these emergency response kits (e.g. A, B, and C Kits).  We find three common failures regardless of the type of Kit: Kit(s) is not inspected “routinely” Kit contents are not managed per their specific requirements (i.e.. hood gaskets) Personnel lack training on applying the Kit(s) Let’s discuss...

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...