I am giving some serious thought to teaching a course I did a number of years ago for a client called "Safety for Process Safety Managers". This client had segregated the PSM/RMP roles from the EHS Group and placed it under the Engineering Group. This caused quite a few problems as the PSM/RMP personnel and the engineering group were vastly unprepared to manage "safety" within their groups. Programs like 1) respiratory protection, 2) control of hazardous energy (LOTO), 3) Permit-Required Confined Spaces (PRCS), 4) Emergency Response (HAZWOPER), and 5) PPE were not written correctly, implemented correctly, and managed properly leading to some significant OSHA/EPA issues as well as INCREASED RISKS. After participating in some on-line discussions with me and other PSM/RMP leaders, the Corporate EHS manager of this company has given me permission to teach this course as an OPEN-ENROLLMENT course to other companies. It was well received by this company; one common statement was "this was an OSHA 10/30 hour on steroids". But I am not sure how many other organizations struggle with PSM/RMP leaders lack of knowledge of these standards and their baseline compliance requirements. If you think this type of training would be of interest to you or your team, please see below...
For those of us that are parents, we know the game of "keeping asking mom and dad in the hopes they'll change their minds" and sometimes I think our profession acts like teenagers and OSHA has to play the role of "mom and dad". Case in point, this OSHA LOI which was posted @ OSHA's LOI page on the use of respirators and facial hair...
Question: If an employee with a neatly trimmed goatee is wearing a respirator and it does not interfere with the seal of the face piece or valve function, and has passed a fit test, does this meet the intent of the OSHA’s Respiratory Protection standard?
OSHA renews it REP for Safety Hazards in Auto Parts Industry – NAICS 3363XX (Motor Vehicle Parts Manufacturing)
The purpose of this instruction is to continue a Regional Emphasis Program to reduce workplace exposures to safety hazards associated in the Auto Parts Supplier Industry. The Notice applies to Atlanta East, Atlanta West, Birmingham, Jackson, and Mobile Area Offices. During FY-16, Region IV conducted 46 inspections coded under the REP. One hundred and forty-three total violations were cited, with the majority of those being violations of the machine guarding and lockout/tagout standards. There was 1 fatality and 3 employer reported referrals coded under this REP in OIS. Four of the inspections resulted in significant cases. All inspections under this program will be comprehensive safety inspections, focusing particularly on Lock Out/Tag Out, Machine Guarding and Electrical Hazards. Additionally, when health hazards are identified, the compliance officer will make a referral to an Industrial Hygienist. The referral inspection is to be opened within 5 working days. CLICK HERE for the REP
PHMSA NOTICE REGARDING THE REQUALIFICATION PERIOD FOR DEPARTMENT OF TRANSPORTATION (DOT) SPECIFICATION CYLINDERS
The U.S. Department of Transportation's Pipeline and Hazardous Materials Safety Administration (PHMSA) has been made aware of concerns regarding newly adopted requirements in Section 180.209(e) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Prior to a January 21, 2016 Final Rule [Docket No. PHMSA-2013-0042 (HM-233F)], the requalification period corresponding to volumetric expansion testing for certain DOT cylinders was 12 years after the initial volumetric expansion testing conducted at the time of manufacture, and 12 years thereafter. The Final Rule, in part, reduced the requalification period from 12 years to 10 years, with a delayed compliance date of January 23, 2017. On January 13, 2017, the National Propane Gas Association (NPGA) submitted a Petition For Rulemaking & Emergency Stay [of] Cylinder Requalification Requirements requesting that PHMSA initiate a rulemaking to replace the requalification requirements established in HM-233F with the former requirements in 49 C.F.R. § 180.209(e). PHMSA hereby gives notice that while it reviews the NPGA Petition for Rulemaking, it will not take enforcement action against a person who requalifies DOT cylinders using volumetric expansion testing pursuant to a 12-year requalification period, as previously authorized by § 180.209( e) in effect on January 22, 2017. We will allow the use of either a 12 or 10-year requalification period for volumetric expansion testing until this notice is rescinded or otherwise modified. This notice is limited to the requirements recently adopted in 49 C.F .R. § 180.209( e ). This notice does not affect any other obligations that offerors or carriers may have under the HMR or any other applicable law. Issued March 17, 2017, in Washington, D.C. Acting Deputy Administrator Pipeline & Hazardous Materials Safety Administration.
The IRSST (Canada) just published a new research report to contribute to confined space accident prevention by helping companies apply existing regulations. Researchers wanted to gain a better understanding of confined space risk management and identify issues based on the literature and field observations, and develop a confined space risk analysis and work categorization tool that meets the needs defined in the first stage of the project. This study provides support for designers, safety officers and rescuers in their respective efforts to improve the health and safe working conditions of people who must enter confined spaces. The tool can be used to design a confined space or to assess an existing one.
EPA RMP citations @ refinery (HF & $ under negotiations)
On November 1, 2016 through November 4, 2016, representatives from the U.S. Environmental Protection Agency (EPA) Region IX conducted an inspection of a refinery to determine compliance with the Risk Management Program (RMP). The preliminary findings of the inspection and additional information request were sent to the refinery and several agencies on March 27, 2017. EPA' s inspection was conducted to determine compliance with the Risk Management Program ("RMP") promulgated under Section 112(r)(7) of the Clean Air Act ("CAA"'), and the General Duty Clause under Section 112(r)(l) of the CAA. The inspection primarily focused on three principal elements of the RMP:
Here is an EXCEL spreadsheet with the "Severe Injuries" reported to OSHA from 1/1/2015 through 9/30/2016. These reports make great content for safety discussions and awareness efforts. You can sort by Hospitalized, Amputation, Injury Nature, Part of Body, Source, Secondary Source. You can also download the full data sheet from OSHA. CLICK HERE (.xls) to download my revised spreadsheet.
For those who manage Lockout-Tagout (LOTO) in a "processing operation" know first-hand how different LOTO is as compared to how its done in an "assembly line" style operation. I have always picked up some "Best Practices" for LOTO at the companies I worked for over the years and as a consultant, I have seen many more at some of my world-class clients. However, I have always struggled to put all of these best practices into one comprehensive document where they all work in concert with one another; that is until some of my international clients recently shared with me... Guideline Mechanical and Process Isolations Major Hazard Standard. This "guide", and yes it is NOT from OSHA or even a USA document, is without a doubt a MUST HAVE for any LOTO lover! Are you looking to take your LOTO program and practices to the next level; this guide will take you there. This guide even provides us with a very sound risk analysis on the different types of energy control methods based on the level of risk involved in the isolation - folks this is just AWESOME! For example, here is a means to semi-quantify the risks associated with tasks and the proper means of energy isolation for said risks... this is JUST PURE SAFETY CAKE: