We often encounter an organization that conducts LOTO training annually. They do this because they believe OSHA requires annual LOTO training. However, the standard, 1910.147, does NOT require annual training! The standard requires each authorized employee to be “inspected” annually. If they fail that inspection, the standard requires the authorized employee to be re-trained. OSHA…...
I think most EHS professionals will agree that bulk tanks of hazardous materials need some means of “secondary containment”. This practice has been in place for my entire career and rarely gets challenged. However, in recent years I have come across several scenarios where either the facility/unit designed the process to function this way or…...
Back in 2010, I posed the question… do the oxygen and acetylene cylinders that are being used to perform the Hot Work need to be 35′ away from the point of the Hot Work? For those who commented, it was clear they thought I was crazy. “It has never been enforced”, “I have been welding/cutting…...
On February 19, 2025, a court sentenced a construction company owner to 48 months’ incarceration and to pay more than $55 million in restitution. Also, he will forfeit real estate and cash/bank accounts. He pleaded guilty to a wire fraud conspiracy, conspiracy to defraud the United States, and a willful violation of the Occupational Safety…...
This video was produced as a companion product to IL OSHA’s report on the Deming Incident where a 20-year-old maintenance worker drowned in an underground vault during an attempt to repair a water main valve. IL OSHA encourages all municipal water departments that enter confined spaces to supplement their employer-specific training curriculum with this video…...
In February 2023, a 20-year-old maintenance worker drowned in a water main vault that flooded during the attempted repair of a leaking valve. IL OSHA determined multiple contributing factors led to the drowning, including: ➡️ Lack of compliance with several confined space standards. ➡️ Lack of oversight and auditing by management. ➡️ Lack of rescue…...
We MUST never be too confident of our written SOPs/JSAs. There is a good reason why “Administrative Controls” are down on the Hierarchy of Controls. When we think our SOPs/Plans are infallible, our workers will show us a thing or two… And when we investigate adverse events and this leads us to “failure to follow…...
Victor Dearman Jr. CIRO, CRST No, it doesn’t involve anything with refrigeration. Same equipment, the same people, and a better layout to improve efficiency. So why would an MOC be required if it doesn’t impact refrigeration/PSM? Well, we have to think a little beyond equipment changes in the refrigeration system for a moment, or procedural
Sometimes a lawyer or set of lawyers can surprise us… This is a quote from a recent OSHRC ALJ decision, regarding the employer’s responsibility to conduct inspections of the workplace to identify and correct hazards: “As an employer, Respondent is obligated to provide safe working conditions and ensure safe work practices. Implicit in that obligation…...
Victor Dearman Jr. CIRO, CRST One of the challenges to my post was “What if the flagging tape was to indicate that the valve was in an abnormal position?” This was followed up with a challenge as to whether or not anything forbids such a method. Operating procedures should be designed to meet the requirements…...
On September 19, 2002, Employee #1 was painting one (1) of six (6) tanks containing carbon dioxide when three (3) of them suddenly exploded. He was killed. The tanks were originally built as railroad tank cars for liquefied petroleum gas and they were not designed to store carbon dioxide…. Membership Required You must be a...
At 7:00 a.m. on October 31, 2022, an employee, 36, was brazing a copper line in an electrical equipment room that was equipped with a carbon dioxide fire extinguishing system. The fire extinguishing system activated, discharging and flooding the room with carbon dioxide. The employee was unable to escape the room and was overcome and…...
