Several million American workers wear respirators on a regular basis, and the Occupational Safety and Health Administration (OSHA) requires that nonagricultural firms have a respiratory protection program. This article uses the OSHA inspection data base to examine all inspections in manufacturing in 47 states from 1999 through 2006; the examination starts with 1999 because an expanded OSHA respiratory program standard became effective in late 1998. The article identifies all inspections and all establishments at which respiratory protection (RP) violations were cited, and it compares the prevalence of violations by industry with the prevalence reported in a recent Bureau of Labor Statistics survey of respirator use. Multivariate analyses are used to identify the roles of industry, establishment size, union status, and employee participation in the inspection on noncompliance at the inspection level and for repeated inspections at the same establishment. The authors find that the pattern of noncompliance across industries mostly mirrors the survey findings about the prevalence of requirements for respirator use, although the chemical industry has fewer violations than expected. The probability of citing an RP violation is similar across establishment size categories, except for a large drop for establishments with over 200 workers. The presence of a worker accompanying the inspector increases the probability that a respiratory program violation will be cited; the presence of a union slightly decreases it.

It has taken me 25 years to diagnose it, but I have finally establish the "Delusional Safety Syndrome" (DSS).  It is the only mental illness known at this time that is actually contagious.  It is spread by close contact with an infected person.  It can lie dormant for years and the infected person can spread the disease before they even recognize they are ill.  Some symptoms include:

This is a follow up to my July 2013 article “Making the case my PSM/RMP covered process complies with RAGAGEPs (Piping)”.  With OSHA’s recent memo on “RAGAGEP in Process Safety Management Enforcement” I have received renewed request to explain how a facility can demonstrate their vessels/tanks comply with RAGAGEP(s).  Here it goes:

Are you providing a copy of 1910.134 Appednix D to each employee who wears a filtering facepieces (dust masks) on a “voluntary basis”? Are you controlling these filtering facepieces (dust masks) so that ONLY employees who have been provided with a copy of Appendix D have access to these filtering facepieces (dust masks)?  For the past 15 or so years I, and I know of many other safety pro’s, have apparently been in error with regards to our obligation(s) when employees wear filtering facepieces (dust masks) on a “voluntary basis”.  I was under the impression that the exception found in 1910.134(c)(2)(ii) exempted the need to have any kind of respiratory protection program if the ONLY respirator used on site involved the voluntary use of filtering facepieces (dust masks).  This is really concerning to me, as I have had dozens of discussions with current and retired OSHA personnel, some as high as Area Director, and it seems that even some OSHA personnel may find this position confusing.  Here's why...

As part of their Industrial Safety Ordinance Contra Costa County, CA developed a VERY NICE safety culture survey.  It is a requirement for CalARP facilities, but just a GREAT RESOURCE for the rest of us.  Check it out Attachment E: Safety Culture Assessment (PDF).  You may have some work to do to get it in a manageable format, but the content is WORLD-CLASS and it is FREE!

Industrial Safety Ordinance
Industrial Safety Ordinance
Industrial Safety Ordinance

When it comes to EPA's Risk Management Plan rule, the state of California made significant modifications to the RMP rule.  Basically, California replaced the Risk Management and Prevention Program with the California Accidental Release Prevention (CalARP) Program on January 1, 1997. The CalARP Program is very similar to the EPA's Risk Management Program with the following differences:

Process or storage vessels and pipe systems that contain ignitable ranges of oxygen and flammable vapors are susceptible to catastrophic explosions. If the oxygen and vapor mixture is ignited by sparks, arcs, friction, compression or other heat sources, the expanding flame front may cause significant injuries and damage. One method of lessening the likelihood of a flash fire is by the installation of a flame arrestor in the equipment or on the end of a vent or process line. Flame arrestors are used in many industries, including refining, oil exploration and production, pharmaceutical, chemical, petrochemical, pulp and paper, sewage treatment, landfills, mining, power generation, and bulk liquids transportation.