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The state of Connecticut is passing a bill to require volunteer fire department or volunteer ambulance company to comply with Conn-OSHA
The state of Connecticut is passing a bill that would require a volunteer fire department or volunteer ambulance company to comply with the state’s Occupational Safety and Health Act (Conn–OSHA) as an employer, unless it is regulated by the federal OSHA law. By law, Conn–OSHA governs workplace safety for the state and its political subdivisions as employers; so, certain non–governmental...
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Congress sends letter to Seqens North America concerning their recent fatal explosion and previous accidents and compliance issues
Senators Markey and Warren and Congressman Moulton have sent a letter to Seqens North America seeking a response to many questions regarding the business’s past accidents and compliance issues.  In the early hours of Thursday, May 4, 2023, an explosion at the Seqens pharmaceutical manufacturing facility in Newburyport injured four workers, with a fifth worker unaccounted for in a facility...
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Hot work on small tanks and drums (UK's HSE)
The UK’s HSE has published a booklet to help manage risks when performing Hot Work (Welding, Cutting, Brazing) on “used containers”.  In the USA, OSHA has some very explicit language in their welding standards… 1910.252(a)(3)(i) Used containers. No welding, cutting, or other hot work shall be performed on used drums, barrels, tanks or other containers until they have been...
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OSHA's new NEP on Falls is not just for construction
This new NEP on falls covers: Roof top mechanical work/maintenance Utility line work/maintenance (electrical, cable) Arborist/tree trimming Holiday light installation Road sign maintenance/billboards Power washing buildings (not connected to painting) Gutter cleaning Chimney cleaning Window cleaning Communication Towers For other non–construction work activities where a worker is observed working...
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Defending H. W. Heinrich's work... The difference between blame (or guilt) and responsibility
We need to note the difference between blame (or guilt) and responsibility. A foreman need not hold himself morally guilty when an employee in his charge is injured, but he cannot and should not evade responsibility under any circumstances whatsoever. Remember that the authority to issue an order involves the responsibility to see that it is properly executed. The country depends upon you—the key...
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Safety Thought of the Week... Culture is generated through the collective experience of practices
Each time the site director has been confronted with a contradiction between safety and production, he has chosen to favor safety, or on the contrary, he has accepted to “adapt” safety rules to achieve a production target. Each time an operator reaches a production target but has taken a risk to do so, the management team will ask him not to do it again, or on the contrary may hold him up as a hero. Managerial...
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Now that the "safety stand-downs" have ended, what now?
As I wrote last week, I am not a fan of the so-called “safety stand-downs” that seem to be all the rage these days.  Our stand-downs in the 1990s and 2000s were entirely different approaches and were conducted following serious events.  My post spurred a lot of great discussions about how they are conducted vs. how they should be conducted and whether we can measure their impact. ...
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EPA EPCRA Survey 2023
Results of EPA's National Survey of State Emergency Response Commissions
I am sharing this report to highlight the weaknesses in the ability of the states to comply with the new emergency response exercise requirements in the RMP rule (40 CFR Part 68.96 Emergency response exercises). In October 2021, the Office of Emergency Management1 (OEM) of the U.S. Environmental Protection Agency conducted a survey of the State Emergency Response Commissions (SERCs) in each state and...
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If you're going to use lagging indicators, at least use them correctly
As the debate in OSH regarding metrics and lagging indicators rages on, there is one aspect to their use that far too many overlook.  If your organization is setting goals using lagging indicators, it should at least be using them correctly.  This means that BOTH FREQUENCY and SEVERITY need to be measured.  I am sure most of us have seen the weakness in measuring the overall injury/illness...
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NTSB N95
Things that make me go hmmm...
That PSV is from a Vinyl Chloride car… so can you see why I am confused by what I see in this NTSB PR pic? Can you name at least two things that make you go Hmmm? Source: https://www.ntsb.gov/news/press-releases/Pages/NR20230321.aspx
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Just because OSHA uses Injury/Illness rates does not mean we should
This week I had an enlighting discussion with another senior management group that was just way off base in their understanding of OSHA’s use of injury and illness rates.  This company is in an industry that is certainly on OSHA’s radar, and their desire to improve safety is simply to reduce their injury and illness rates so they are less likely to receive an OSHA inspection than their...
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OSHA should take note of the UK's HSE approach to SMS
With the latest news of the Appeals Court case that could cause 50 years of OSHA standards to be unwound, the UK’s HSE weekly newsletter reminds us of how safety should be managed.  OSHA’s old compliance model has run its course.  I am NOT advocating we do away with OSHA standards, as I believe they have their role in society.  But for most employers, we have to move beyond...
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