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...

I know by the poll results and the emails/texts/calls I have received these past 2-3 weeks that this post will be met with a healthy dose of skepticism, but that has never stopped me from saying what I believe when it comes to the safety and health of those we have the privilege to protect.  So, I hope to spark many more discussions with this series of articles titled “Is shorter better?“...

I came across these helpful tips for our Safe Work Permitting System.  I hope it can help others… … HomeRead More »

Today, my “friend in safety” and I continued our debate/discussion regarding the “proper” length of written programs. He staunchly believes that a shorter program will attract more eyes and get used more often. On the other hand, I have programs that are over 50 pages, which blows his mind. He brought a few samples of his written programs, which helped me make my point.  ...

Much can be said about the safety movement mimicking the 1990s Quality Movement in the US automobile industry. Does anyone remember Ford’s “Quality is Job 1” ads? It was a huge branding image effort to compete with Toyota and Honda, who were stealing market share based on the QUALITY of their vehicles. Even today, Toyota and Honda (as well as some other foreign manufacturers) have...

This past week, we saw the 2nd catastrophic failure of an NH3 nurse tank in three months.  This is indeed a rare occurrence.  Both incidents appear (from news accounts and photos) to be circumferential weld failures on these vessels.  Both vessels failed while they contained NH3 (levels unknown), but neither was actively being filled at the time of their failure.  The incident this...

Does it bother anyone when we see this sign? I am not telling you anything you don’t already know… Hearing Protection is very much like Respiratory Protection – it comes with some serious limitations and is based on the worker’s EXPOSURE. However, as a consultant working in plants, I am always told in my contractor safety package that I have to wear hearing protection when entering...

I am not a big fan of government intervention, but in the safety envelope, they play a role in validating that minimum standards are being met.  The Federal Motor Carrier Safety Administration (FMCSA) audits service providers who inspect HAZMAT transportation containers.  Beginning in June 2023, during an investigation at a manufacturer in Fresno, California, FMCSA personnel discovered that...

PHMSA proposes revisions to the pipeline safety regulations to require operators of gas distribution pipelines to update their distribution integrity management programs (DIMP), emergency response plans, operations and maintenance manuals, and other safety practices These proposals implement provisions of the Leonel Rondon Pipeline Safety Act—part of the Protecting our Infrastructure of Pipelines and...

I don’t think many safety pros would argue with this statement:  LOTO requires that all forms of hazardous energy be taken to a ZES before servicing and maintenance begin. But I have had many discussions about DEFINING and QUANTIFYING what a “hazardous form of energy” is.  Since OSHA has not quantified the term “hazardous energy”, many written LOTO programs and...

The United States Court of Appeals for The Sixth Circuit says it does.  More than fifty years ago, Congress passed, and President Nixon signed into law, the Occupational Safety and Health (OSH) Act, 29 U.S.C. § 651 et seq. Throughout the next half century, challenges to the constitutionality of the Act have been uniformly rejected. See Nat’l Mar. Safety Ass’n v. Occupational Safety & Health...

Earlier this month, I wrote Cuts so deep that workers can’t participate in their safety process concerning how reorganizational changes can lead to a lean workforce that the workers who need to participate in their safety process do not have the time to.   Now, let’s take a look at what happens when the layer of field supervision is cut so deep that we lose the ability to have...