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2014 Photo of the Week #48 (Ladders)
Safety Info Posts - Photo of the Week
Written by Bryan Haywood   
Saturday, 22 November 2014 13:33


Last Updated on Saturday, 22 November 2014 13:35
2014 Video of the Week #48 (Jase and Uncle Si Turkey Frying Safety Video w/ State Farm)
Safety Info Posts - Video of the Week
Written by Bryan Haywood   
Friday, 21 November 2014 00:00

Hang on a Minute with Si and Jase from MultiVu Video on Vimeo.

Last Updated on Friday, 21 November 2014 15:04
OSHRC decision on Combustible Dusts (OSHA Dust Sampling, Chain of Custody, Knowledge of hazards, and Signage for ComDust areas)
Safety Info Posts - OSHA Compliance Posts
Written by Bryan Haywood   
Thursday, 20 November 2014 20:32

Facility manufactures over 600 small animal products, including bird food, but not dog and cat food, which are sold in small and large chain pet stores. Fifty to 60 employees work in its 120,000 square foot production facility and warehouse. Part of the facility, measuring 8,000 to 10,000 square feet, is devoted to assembling small animal products from 2500 types of raw materials, including millet seeds, milo, safflower seeds, sunflower seeds, corn, wheat, oats, papaya, pineapple, flaked peas, raisins, dates, corn flakes, banana chips, flower petals, and poppy seeds. Adjacent to this assembly room, located on an outside corner of the first floor of the facility, is the “dust room,” which is the focus of this case. In another part of this facility, located away from the dust room, is the “hay room,” which is devoted to hay-related products. The hay room is about 1500 square feet and was the focus of a previous OSHA inspection in 2008.

Last Updated on Thursday, 20 November 2014 20:41
OSHRC decisions on Machine Specific LOTO Procedures, LOTO Periodic Inspections, and LOTO Training for Affected/Other employees
Safety Info Posts - OSHA Compliance Posts
Written by Bryan Haywood   
Thursday, 20 November 2014 14:46

These LOTO decisions by the OSHRC are HUGE in establishing some "minimums" for LOTO procedures, periodic inspections, and training for "affected" and "other" employees.  Readers should pay very close attention to the details that OSHA used in their arguments of how poorly "machine specific procedures" were written (missing data, conflicting data, no magnitudes listed, etc.).  The facility really wasted the courts time with their arguments (my professional opinion) as OSHA had their ducks in a row AND the facility made it easy for OSHA... i.e. plenty of low hanging fruit for OSHA to pick from within their LOTO program!!!  Here are the LOTO decisions:

NOTE: this case also involved a machine guarding decision that can be seen in the full decision.

Last Updated on Thursday, 20 November 2014 15:18
EPA RMP Citations @ Cold Storage Facility (NH3; $124K)
Safety Info Posts - PSM and RMP Citations/Analysis
Written by Bryan Haywood   
Wednesday, 19 November 2014 22:10

Respondent owns and operates a controlled-temperature storage warehouse for food products. The Facility is located adjacent to Interstate 91 and east of the Quinnipiac River, within a mile of numerous shops and business and approximately 1 mile from several schools. Respondent uses anhydrous ammonia in a refrigeration "process".  In 2009, Respondent filed a Program 3 RMP for the Process and reported that it used 22,600 pounds of anhydrous ammonia. Respondent's most recent RMP re-submission, in 2013, again reported that one Program 3 process uses 22,600 pounds of ammonia. Accordingly, the Process is a "covered process" subject to the provisions of Part 68 because Respondent "uses," "stores," and "handles" the RMP chemical anhydrous ammonia at the Facility in an amount greater than 10,000 pounds. According to Respondent's RMP, there are public receptors within the distance to the endpoint for a worst case release of the amount of anhydrous ammonia used in the Process. Likewise, modeling performed by EPA indicates that the endpoint for a worst case release from each Process is greater than the distance to a public receptor. Additionally, the Process is subject to OSHA's PSM requirements at 29 C.F.R. § 1910.119 because it uses anhydrous ammonia in an amount over the threshold quantity of 10,000 pounds. Therefore, in accordance with 40 C.F.R. § 68.10(a}-(d), Respondent's use, storage, and handling of anhydrous ammonia in its Process is subject to the requirements of RMP Program 3. On October 18, 2012, EPA inspectors visited the Facility ("Inspection") to assess Respondent's compliance with Section 112(r) of the CAA and with Sections 302-312 of the Emergency Planning and Community Right-to-Know Act.  Here is a breakdown of the citations:

Last Updated on Wednesday, 19 November 2014 22:26
39 incidents & 0 updates (11/19/14)
Safety Info Posts - Incident Alerts
Written by Bryan Haywood   
Wednesday, 19 November 2014 20:42
OSHA's First Aid and BBP training requirements
Safety Info Posts - Emergency Response
Written by Bryan Haywood   
Tuesday, 18 November 2014 10:38

A very common question we get during our work is... "Am I required to have a first aid team on site?" And "If I am, do they fall under the Blood Borne Pathogen standard"?  OSHA actually provided us some great insight into their position on these questions in a 2007 LOI.  They stated...

OSHRC upholds WILFULL GDC with Postal Carrier Fatality due to Heat Stroke
Safety Info Posts - OSHA Compliance Posts
Written by Bryan Haywood   
Friday, 14 November 2014 19:50

WOW... you want to read a case from !@#$, this will be some interesting reading for you.  If there was ever a case where the lesson is "Do as you say you're going to do in your safety program" this case is the "poster child" for that cause.  Too many strikes against the management at the USPS to list so I am just going to provide the link to the case, but this is without a doubt one of the best investigated cases in the history of OSHA!  To get a Willful on the General Duty Clause is tough, but they nailed this one and there are plenty of learning's for everyone in this case.  CLICK HERE for the case file.

OSHRC determines that a zip tie does NOT constitutes a “permanent” fixture
Safety Info Posts - OSHA Compliance Posts
Written by Bryan Haywood   
Friday, 14 November 2014 19:24

This case makes two (2) decisions that on the surface appear to be a step backwards - but readers should not read anything into these decisions!  The refrigerator in the power strip was lost merely because the CSHO did NOT document the power pull the refrigerator was putting on the power strip.  So before we go thinking that we can plug our refrigerators into power strips SAFELY or use zip ties to fasten our power stips to the building - think TWICE.

Complainant alleged a serious violation of the Act in Citation 1, Item 2 as follows:

29 CFR 1910.303(b)(2): Listed or labeled electrical equipment was not used or installed in accordance with instructions included in the listing or labeling:
a) Kitchen area: On June 3, 2013 and at times prior, employees were exposed to fire and shock hazards from overloading a relocatable power tap used to energize a “True Manufacturing” food preparation table/refrigerator. Relocatable power taps are only listed to be used for low ampere devices such as computers and their peripherals.

Last Updated on Friday, 14 November 2014 19:50
Testing for water in your Ammonia Refrigeration Process
Safety Info Posts - Chemical Process Safety (PSM/RMP)
Written by Bryan Haywood   
Friday, 14 November 2014 11:47

cold-flo sample drawingA while back I was participating in a PHA of a refrigeration process and somehow the discussion led to one that sort of scared me a bit... collecting a liquid ammonia sample to test for water content.  The actual art of ammonia refrigeration not being my areas of expertise, I had always reserved Bulletin No. 108. Guidelines for Water Contamination in Ammonia Refrigeration Systems for a rainy day reading project (which never came by the way).  I focused more on the process safety related items and thought water contamination was merely a production/energy issue and therefore no safety/health risks.  That was MY IGNORANCE and now I am kicking myself in the ass for missing this task in previous PHA/JHA’s and Audits.  But having asked around of many of my friends and clients in the refrigeration industry I have come to realize that I may not be the only ignorant ass safety professional when it comes to catching liquid ammonia samples!  Here are my questions and concerns with the task...

Last Updated on Monday, 17 November 2014 16:42

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I worked with Bryan to get his views on an upcoming Ammonia Refrigeration Process Safety publication. We spent an entire day going over the work and his input was of excellent value. Bryan understands Process Safety on a deep level and brings a wealth of knowledge concerning best practices to the...

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Date: Jan 31, 2012