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MEMBERS AREA updated on 2/27/2017 with 187 photos and 37 documents
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In OSHA's LOTO standard (1910.147) the agency included in their definition of an "lockoout device" a "blank flange" and "bolted slip blind", when in fact these device are actually "energy isolation devices". So why would OSHA consider these devices a "lockout device"?
NOTE: I am not in agreement with this and have never called a "blank flange" and "bolted slip blind" a "lockout device", but rather energy isolation devices. This may seem like semantics, but it is HUGE in the world of energy control!
In the Final Rule, OSHA determined that lockout is a surer means of assuring deenergization of equipment than tagout, and that it is the preferred method. However, the Agency also recognized that tagout will nonetheless need to be used instead of lockout where the energy control device cannot accept a locking device. Where an energy control device has been designed to be "lockable", the standard REQUIRES that lockout be used unless tagout can be shown to provide "full employee protection," that is, protection equivalent to lockout. But what does OSHA consider to be "locakable"?
Enforcement of minimum approach distance requirements in 29 CFR 1910.269 and 29 CFR Part 1926, Subpart V
On April 11, 2014, OSHA promulgated a final rule revising the general industry and construction standards for work on electric power generation, transmission and distribution installations. On February 13, 2015, OSHA entered into a settlement agreement with the Edison Electric Institute, the Utility Line Clearance Coalition, and the Tree Care Industry Association resolving legal challenges to that final rule. As part of that settlement, OSHA issued a memorandum (dated February 18, 2015) with the subject line "29 CFR 1910.269 and 29 CFR Part 1926, Subpart V-Enforcement dates." The memorandum adopted a delayed enforcement date for certain minimum approach distance requirements in 29 CFR 1910.269 and 29 CFR Part 1926, Subpart V. On January 20, 2016, OSHA issued a second memorandum (subject line, "29 CFR 1910.269 and 29 CFR Part 1926, Subpart V-Enforcement dates for minimum approach distances") further delaying enforcment of those requirements. This memorandum further extends those enforcement dates as follows:
OSHA clarifies the NRTL listing/approval requirements for non-electrical vacuum cleaners used in combustible dust atmospheres (OSHA LOI)
Scenario: Some equipment manufacturers believe that all equipment used in combustible dust atmospheres, including non-electrically powered vacuum cleaners, requires NRTL listing/approval.
Question: Could OSHA clarify the NRTL listing/approval requirements for non-electrical vacuum cleaners used in combustible dust atmospheres?
I have been given permission to OPEN up a PSM Training course in April to other clients/members. This is a 4.5 day training course and involves field-work, so you will need to bring your PPE (Safety Glasses, Safety Boots, Hard-Hat, and FRC if you have it). The course will be taught with a focus on Category 1 FLAMMABLE HHC, but this is such a detailed course we learn principles and RAGAGEPS that cover many of the more popular toxics. This is NOT an introductory course, this course is designed for professionals who develop, implement, measure, and manage process safety management systems. Here is the agenda and other details:
This case is yet another example of how "legal" and "safety" can be so far apart from each other. This case was won by the company because OSHA did a horrible job in defending their citation; and yet, it will become ammo for companies to use in future cases. Let's not fool ourselves into believing that a 1/4" opening around a conveyor does not present a hazard. In this case, a young lady lost her index finger when she tried to remove a piece of chicken from this 1/4" opening between a conveyor and a plastic back splash. The company argued that 1/4" openings are deemed acceptable in all guarding AND that this area did not need to be guarded because the rate of the chicken cone conveyor was too fast, thus never allowing the employees to reach into the opening. BOTH of these arguments are badly flawed based on the facts that: 1) an employee reached into the gap and 2) had her finger amputated; yet the review commission vacated the citation based 100% on the legal argument and the fact that OSHA could not defend it's citation. So yes the company "won", but there is a lot of safety we can learn from this case. By the way, I personally would have cited 1910.147 seeing how she was "cleaning" or "clearing a jam" when she reached into the opening to remove the chicken and the conveyor had not been locked out.
A poultry processing plant was inspected following a reported finger amputation. OSHA commenced an inspection of the worksite on July 1, 2015, with an additional site visit on July 29, 2015. As a result of the inspection, a Citation was issued alleging a violation of 29 C.F.R. § 1910.212(a)(1) and proposed a $7,000.00 penalty.
Over my career in safety I have seen the use of "welding carts" spin out of control as if they are all the "almighty" in fire prevention. These carts can now be purchased with a 30-minute "fire wall" between the fuel gas (e.g. acetylene, propane, etc.) and the oxidizer (e.g. oxygen) and in fact do comply with both OSHA and NFPA storage requirements. But these carts are not keeping up with the newest code requirements and may be on their way out. Many states utilize the International Fire Code (IFC) as a baseline "fire safety code" within their state. The IFC has had a unique separation requirement for fuel gases and oxidizers for several of the last revisions that now make the vast majority of these carts obsolete when it comes to 100% compliance - 100% of the time. Now don't get me wrong, I am in NO WAY suggesting that we trash our carts today as they still comply with OSHA and NFPA requirements, but just like any other safety/control device - we MUST MANAGE them properly and understand their LIMITATIONS.
Respondent owns and operates a facility that produces, processes, handles, and/or stores a regulated extremely hazardous substance, anhydrous ammonia. The facility uses anhydrous ammonia in a closed-circuit refrigeration system to produce and store ice. Though the ice maker process runs continually, employees are not normally present at the facility outside of business hours. On March 15, 2016, at 22:53, the city Fire Department was notified of a potential release at the facility. Firefighters who responded to the facility believed there had been an anhydrous ammonia release and confirmed that ammonia was in the air by using atmospheric monitoring. The Fire Department notified Respondent's operations manager of the release from the facility. Respondent's employees came to the facility and worked with the Fire Department to stop the release. Following Fire Department protocol, firefighters donned HAZMAT suits to enter the Facility and shut down the compressor. Firefighters remained on site monitoring the air until 05:57 on March 16.
I guessing engineering thought this was a new manual fire protection system for electronic systems!!! And sadly, if we look closely at the wall across from this safety disaster you may recognize their VPP STAR banner hanging!!! The new safety shower was an action item from their VPP assessment.