The client this week had such an eye-opening experience with the risk assessment yesterday; they were all early this morning and had written out their homework assignment for the night! We took their loading docks and did the OSH version of LOPA called a Hierarchal Analysis around workers being crushed by a trailer at the docks and forklifts falling off a dock or out of a truck as it pulls away. We...

As safety pros return to work this week from the annual ASSP conference last week, their excitement and enthusiasm will either blossom or bottom out.  So many new techniques are being pushed in the safety arena these days, and many safety pros and management personnel are grasping for whatever it takes to turn their safety performance around.  So with all these ground-breaking techniques...

During offshore energy operations, a worker was recently injured while attempting to install a hydraulic line on a pipe-handling machine. The worker determined that the combination wrench on hand was too long for this particular use and attempted to manually alter the tool by placing the wrench into a vice to shorten the length using a hacksaw. During the wrench alteration process, the worker cut a...

Thanks to Ross W Skaggs, CSP (ret) , for another pic – follow him @ LinkedIn for more. Today’s pic will make you scratch your head and maybe wonder how that could happen. “No Parking” signs may be one of society’s most widely used signs.  They convey a simple directive, yet can you guess the #1 non-moving violation on our roadways?  Yep, parking violations. ...

We are all familiar with OSHA’s LOTO Periodic Inspection requirements (1910.147(c)(6)).  It is a topic of great debate, still in the Year 2023.  But there is a serious, I say it is a fatal flaw in the periodic inspection process. It is common for this activity to be performed by managers/supervisors who are authorized in the LOTO program and have direct supervision of the employees...

When people say, “safety is just common sense,” I wish we could slap them.  Working for a client in KY, I have identified so much that is different between their state plan and the federal OSHA requirements.  Some of the differences just do not make sense and I am sure there are some political forces behind the lack of “risk sense” in these differences.  For example,...

As with some state plans, KY-OSHA has some standards that are more in-depth than the federal version.  Although, a couple of years ago, the KY legislature passed a bill that restricts KY-OSHA from adopting any standards that are more stringent than federal OSHA.  But for now, KY-OSHA’s 1st Aid standard goes much further than federal OSHA. The employer shall ensure the ready availability...

Where an employee is confronted with a choice between not performing assigned tasks or being subjected to death or serious injury arising from a dangerous condition at the workplace, such employee may refuse in good faith to expose himself/herself to the dangerous condition. The condition causing the employee’s apprehension of death or injury must be of such a nature that a reasonable person...

A “Hazardous liquid” means, for the purpose of this regulation, a chemical or mixture of chemicals that is toxic, an irritant, corrosive, a strong oxidizer, a strong sensitizer,combustible, flammable, extremely flammable, dangerously reactive or pressure generating or which otherwise may cause substantial personal injury or substantial illness during, or as a direct result of any customary...

I am not trying to start another LOTO fight about Lockout vs Tagout, but for those who do work in the state of KY, it is important to know that KY-OSHA does NOT allow an employer to utilize TAGOUT when the device can accept a lock.  This is different than what Federal OSHA allows.  Federal OSHA allows Tagout in lieu of Lockout as long as the employer can demonstrate that the Tagout provides...

Recently I was working with a client on some LOTO procedures, and I was out, and about in the plant, and as I was tracing down an airline, something caught my eye.  At first, I was not sure if I was just seeing things, as in my safety mind, there was just no way anyone would be where I was praying they were not.  I WAS WRONG!  As you can see in pics #1 and #2 below, that is a worker...

One of the things that EPA learned from OSHA’s roll-out of their PSM standard was that not everyone recognized the standard as a 14-element management system.  So when it came time for EPA to roll out its RMP, they made a “management system” part of its requirements.  However, EPA quickly disappointed when they said all that was needed was an organizational chart showing...