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In this week’s Newsletter


  •  More indications of OSHA’s push for Flame Retardant Clothing (FRC)

  •  Pipeline Accident Report: San Bruno, CA, Natural Gas Pipeline Explosion and Fire, September 9, 2010

  •  Barriers to Occupational Injury Reporting by Workers

  •  Clarification on whether an exercise regime is first aid or medical treatment

  •  Tech Talk® Webinar covers flammable liquid storage

  •  States Cracking Down on Drunk Drivers

Side Bar Items:

  •  SAFTENG Blog & SAFTENG LinkedIn Forum
  • Safety and Health Tip – WISER for Android 
  • Civilian Fire Fatalities
  • Safety Recalls
  • EHS Events

More indications of OSHA’s push for Flame Retardant Clothing (FRC)

OR-OSHA’s recently released their PPE Directive, which differs from the Federal OSHA PPE Directive in how Flame Retardant Clothing issues are addressed.  The Federal Directive covers who has to pay for the FRC, but OR-OSHA goes a bit further by having their CSHO’s reference NFPA 2112, Standard on Flame- Resistant Garments for Protection of Industrial Personnel Against Flash Fire, and NFPA 2113, Standard on Selection, Care, Use, and Maintenance of Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire.  Here is what their Directive states.


PROCEDURES: Determine whether the following items are in compliance with the standard:

A. Flame-resistant (FR) clothing. Employers are required to provide, at no cost to employees, FR clothing for applications such as, but not limited to, the handling of flammable chemicals. Cite 1910.132(a), for failure to provide and ensure the use of flame-resistant clothing necessary to protect employees from burns due to flash fires.

Cite 1910.132(b), for failure to ensure that employee-owned FR clothing is properly maintained and sanitary.

Cite 1910.132(c), for failure to provide FR clothing that is of safe design and construction for the work being performed. Refer to consensus standards such as NFPA 2112, Standard on Flame- Resistant Garments for Protection of Industrial Personnel Against Flash Fire, and NFPA 2113, Standard on Selection, Care, Use, and Maintenance of Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire.

Click Here (pdf) for the entire directive.

Pipeline Accident Report: San Bruno, CA, Natural Gas Pipeline Explosion and Fire, September 9, 2010

Lessons we can apply to our Process Safety Management Systems

On September 9, 2010, about 6:11 p.m. Pacific daylight time, a 30-inch-diameter segment of an intrastate natural gas transmission pipeline known as Line 132, owned and operated by the Pacific Gas and Electric Company (PG&E), ruptured in a residential area in San Bruno, California. The rupture occurred at mile point 39.28 of Line 132, at the intersection of Earl Avenue and Glenview Drive. The rupture produced a crater about 72 feet long by 26 feet wide. The section of pipe that ruptured, which was about 28 feet long and weighed about 3,000 pounds, was found 100 feet south of the crater. PG&E estimated that 47.6 million standard cubic feet of natural gas was released. The released natural gas ignited, resulting in a fire that destroyed 38 homes and damaged 70. Eight people were killed, many were injured, and many more were evacuated from the area.

1910.119(j)(6) Quality assurance

The National Transportation Safety Board's investigation found that the rupture of Line 132 was caused by a fracture that originated in the partially welded longitudinal seam of one of six short pipe sections, which are known in the industry as "pups." The fabrication of five of the pups in 1956 would not have met generally accepted industry quality control and welding standards then in effect, indicating that those standards were either overlooked or ignored. The weld defect in the failed pup would have been visible when it was installed.

1910.119(n) Emergency planning and response

The rupture occurred at 6:11 p.m.; almost immediately, the escaping gas from the ruptured pipe ignited and created an inferno. The first 911 call was received within seconds. Officers from the San Bruno Police Department arrived on scene about 6:12 p.m. Firefighters at the San Bruno Fire Department heard and saw the explosion from their station, which was about 300 yards from the rupture site. Firefighters were on scene about 6:13 p.m. More than 900 emergency responders from the city of San Bruno and surrounding jurisdictions executed a coordinated emergency response, which included defensive operations, search and evacuation, and medical operations. Once the flow of natural gas was interrupted, firefighting operations continued for 2 days. Hence, the emergency response by the city of San Bruno was prompt and appropriate.  However, PG&E took 95 minutes to stop the flow of gas and to isolate the rupture site - a response time that was excessively long and contributed to the extent and severity of property damage and increased the life-threatening risks to the residents and emergency responders. The National Transportation Safety Board found that PG&E lacks a detailed and comprehensive procedure for responding to large-scale emergencies such as a transmission pipeline break, including a defined command structure that clearly assigns a single point of leadership and allocates specific duties to supervisory control and data acquisition staff and other involved employees. PG&E's supervisory control and data acquisition system limitations caused delays in pinpointing the location of the break. The use of either automatic shutoff valves or remote control valves would have reduced the amount of time taken to stop the flow of gas.

1910.119(j) Mechanical integrity

PG&E's pipeline integrity management program, which should have ensured the safety of the system, was deficient and ineffective because it ----Was based on incomplete and inaccurate pipeline information (1910.119(d) Process safety information)

-Did not consider the design and materials contribution to the risk of a pipeline failure. (1910.119(e) Process hazard analysis)

-Failed to consider the presence of previously identified welded seam cracks as part of its risk assessment.

-Resulted in the selection of an examination method that could not detect welded seam defects. (1910.119(j)(4)(ii) Inspection and testing procedures shall follow recognized and generally accepted good engineering practices)

-Led to internal assessments of the program that were superficial and resulted in no improvements.

Several deficiencies revealed by the National Transportation Safety Board investigation, such as PG&E's poor quality control during the pipe installation and inadequate emergency response, were factors in the 2008 explosion of a PG&E gas pipeline in Rancho Cordova, California. (See Explosion, Release, and Ignition of Natural Gas, Rancho Cordova, California, December 24, 2008, Pipeline Accident Brief NTSB/PAB-10/01 (Washington, DC: National Transportation Safety Board, 2010)). This 2008 accident involved the inappropriate installation of a pipe that was not intended for operational use and did not meet applicable pipe specifications. PG&E's response to that event was inadequate; PG&E initially dispatched an unqualified person to the emergency, causing an unnecessary delay in dispatching a properly trained and equipped technician. The National Transportation Safety Board concluded that PG&E's multiple, recurring deficiencies are evidence of a systemic problem.  The investigation also determined that the California Public Utilities Commission, the pipeline safety regulator within the state of California, failed to detect the inadequacies in PG&E's integrity management program and that the Pipeline and Hazardous Materials Safety Administration integrity management inspection protocols need improvement. Because the Pipeline and Hazardous Materials Safety Administration has not incorporated the use of effective and meaningful metrics as part of its guidance for performance-based management pipeline safety programs, its oversight of state public utility commissions regulating gas transmission and hazardous liquid pipelines could be improved. Without effective and meaningful metrics in performance-based pipeline safety management programs, neither PG&E nor the California Public Utilities Commission was able to effectively evaluate or assess PG&E's pipeline system.  Click Here for more on this incident.


Barriers to Occupational Injury Reporting by Workers

Each year about 5,400 workers die from a work-related injury and 4 million private industry workers report a nonfatal injury or illness. There are 3.4 million workers treated in U.S. hospital emergency departments annually for nonfatal occupational injuries and illnesses. Although studies indicate that we have reduced the number of nonfatal injuries in recent decades, there is evidence that nonfatal occupational injury surveillance significantly underreports workplace injuries. This presumed undercount potentially decreases health and safety funding because of a false sense of improvement in the occupational injury rates. It also increases the misdirection of scarce safety and health resources because hazardous workplaces are not appropriately identified or assessed and intervention efforts cannot be properly targeted or evaluated. It is this basic need for reliable and comprehensive occupational injury surveillance that led to the 1987 National Academy of Science report Counting Injuries and Illnesses in the Workplace--Proposals for a Better System and the 2008 Congressional Report Hidden Tragedy: Underreporting of Workplace Injuries and Illnesses.  The proposed pilot research addresses two facets of nonfatal occupational injury reporting noted in these reports--understanding barriers and incentives to reporting occupational injuries and using this knowledge to assess and improve our surveillance activities. The objectives of this project are to (1) characterize and quantify the relative importance of incentives and disincentives to self-identifying work-relatedness at the time of medical treatment and to employers; (2) characterize individual and employment characteristics that are associated with non-reporting of workplace injuries and incentives and disincentives to reporting; (3) test the reliability of hospital abstractors to properly distinguish between work-related and non-work-related injuries; and (4) evaluate the feasibility, need, and requirements for a future larger study. Results will be disseminated in multiple forms to reach a variety of occupational health and safety stakeholders.  This project will use the occupational and the all injuries supplements to the National Electronic Injury Surveillance System (NEISS-Work and NEISS-AIP, respectively) to identify telephone interview survey participants. NEISS-Work and NEISS-AIP, collected by the Consumer Product Safety Commission (CPSC), capture people who were treated in the emergency department (ED) for a work-related illness or injury (NEISS-Work) or any injury, regardless of work-relatedness (NEISS-AIP). Interview respondents will come from two subgroups-- individuals treated for a work-related injury and individuals who were treated for a non-work-related injury but who were employed during the time period that the injury occurred.

Clarification on whether an exercise regime

is first aid or medical treatment

OSHA clarifies whether an exercise regime directed by a Certified Athletic Trainer (ATC) would constitute "first aid" or "medical treatment" for OSHA injury and illness recordkeeping purposes. In general, if the ATC recommends exercise to an employee who exhibits any signs or symptoms of a work related injury, the case involves medical treatment and is a recordable case.  OSHA discussed the issue of therapeutic exercise in the preamble to the final rule revising OSHA's injury and illness recordkeeping regulation. See, 66 FR 5992, January 19, 2001.  OSHA stated that it considers therapeutic exercise as a form of physical therapy and intentionally did not include it on the list of first aid treatments in Section 1904.7(b)(5)(ii).  Section 1904.7(b)(5)(ii)(M) states that physical therapy or chiropractic treatment are considered medical treatment for OSHA recordkeeping purposes and are not considered first aid.  Section 1904.7(b)(5)(iii) goes on to state that the treatments included in Section 1904.7(b)(5)(ii) is a comprehensive list of first aid treatments.  Any treatment not included on this list is not considered first aid for OSHA recordkeeping purposes.  Please be aware that if a treatment is administered as a purely precautionary measure to an employee who does not exhibit any signs or symptoms of an injury or illness, the case is not recordable.  For a case to be recordable, an injury or illness must exist.  For example, if, as part of an employee wellness program, an ATC recommends exercise to employees that do not exhibit signs or symptoms of an abnormal condition, there is no case to record.  Furthermore, if an employee has an injury or illness that is not work-related, (e.g., the employee is experiencing muscle pain from home improvement work) the administration of exercise does not make the case recordable either.  Your letter also requested specific guidance on several questions concerning the administration of exercise.  For purposes of this response, we presume that all of the questions relate to the administration of exercise as a treatment for work-related injuries.

  • Would the providing of an employee with a written home exercise program (including sets/reps and resistance) constitute first aid or medical treatment?  This constitutes medical treatment. 
  • If the ATC utilizes stretching to relieve their symptoms, does this service constitute medical treatment or first aid? This constitutes medical treatment. 
  • Is the number of times seen for care significant in determining recordability? No. The number of times seen for care is not a factor when determining OSHA recordablity. The focus is on the type of treatment rather than the number of times such treatment is administered. 
  • Is the duration or intensity of the care significant in determining recordability? No. The duration or intensity of the care does not determine recordablity. Again, the focus is on the type of treatment. 
  • Are the numbers of follow-ups significant in the recordability of the care? No. The number of follow-up visits to receive care does not determine the outcome for an OSHA recordable. 
  • Is there a general guideline that an ATC can use to know if they are crossing the line from first aid to medical treatment? In general, first aid can be distinguished from medical treatment per Section 1904.7(b)(5)(ii) and 1904.7(b)(5)(iii). As noted above, Section 1904.7(b)(5)(ii) states that the list of first aid treatments included in Section 1904.7(b)(5)(iii) is comprehensive.  Any treatments not included on the list would not be considered "first aid" for OSHA recordkeeping purposes.  
Click Here to see the entire LOI.


Tech Talk® Webinar covers flammable liquid storage 

Lab Safety Supply is hosting a Tech Talk® webinar Sept. 21, 2011 at 1 p.m. CDT entitled "Flammable Liquid Storage 101." The Tech Talk® will cover both the OSHA and NFPA standards applying to flammable liquids in the workplace and address some commonly asked questions regarding compliance.  Lab Safety Supply Technical Support Specialist John Eliszewski will host the 30-minute Tech Talk®. In addition to 10 years of experience handling questions on Lab Safety Supply's Safety TechLine®, Eliszewski has a B.S. in Occupational Safety and a Masters in Safety and Loss Control.  If you're interested in attending, please This email address is being protected from spambots. You need JavaScript enabled to view it. and company name with "Flammable Liquid Storage 101" in the subject line.

PLEASE NOTE:  I am in NO WAY endorsing this webinar.  I just know a lot of businesses struggle with flammable liquid safety and this may be a FREE opportunity to pick up some good info. 


States Cracking Down on Drunk Drivers

September 2nd is the Second Most Deadly Day of the Year on Roadways

Drunk driving is not an accident--it's blatant disregard for human life. In 2009, nearly 11,000 people died in crashes in which a driver or motorcycle rider was at or above the legal alcohol limit. This is why GHSA's member State Highway Safety Agencies are joining forces with the U.S. Department of Transportation's National Highway Traffic Safety Administration (NHTSA) and local officials to conduct the national Drive Sober or Get Pulled Over Labor Day drunk driving crackdown.  A full list of state-specific crackdown efforts is available on GHSA's website at:  For current drunk driving laws, visit: To view the announcement from the U.S. DOT, visit  


SAFTENG LinkedIn Forum  

Click Here to Join the Safety Engineering Network (SAFTENG) Forum on LinkedIn forum.  It's FREE! We now have 1,306 members  

NOTE:  If you and I are not "Linked" send me an invitation and I will accept.  I accept ALL invitations from safety professionals.  Also, if you use LinkedIn PLEASE consider joining the Safety Engineering Network LinkedIn Forum. 

Topics this week:

  •  SAFETY ALERT - Incorrectly Refurbished Circuit Breakers
  •  Automatic Sprinklers: Sprinkler Spacing From Walls
  •  NTSB cites PG&E and government oversight in fatal California pipeline rupture
  •  Flammable Liquid Storage Tanks and Venting
  •  Wood dust exposure video
  •  CDC Responds to Hurricane 2011 Season
  •  23 Incidents & 2 Updates (8/29/11)
  •  The shark in the street photo was FAKE!!!
  •  How to get the certified safety professional (CSP) certification online?
  •  New generation and risk perception
  •  Video of the Week - Crane accident and rescue caught on tape
  •  Conventional poly rather than fire retardent
  •  "Hats off Test"... the life of a hard hat thru its testing
  •  CPSC and USFA Warn About Deadly Dangers That Can Linger After Hurricane Irene Passes
  •  Refinery NEP Inspection Results Attachment B
  •  Six criteria for safety excellence
  •  Worker safety rulemaking 101, Part 2
  •  Fire out, Lincoln mulls propane facility risks - and who'll pay bill
  •  WISER for Android - Android Market

Jobs posted on SAFTENG LinkedIn Forum:

  •  Plant Safety and Environmental Manager near Lafayette, Indiana - salary to 110K plus bonus and relocation
  •  Safety Consultant - Schaumburg, IL area with salary up to 70K
  •  Q&R candidates with expereince in ISO 13485 and CAPA
  •  Company is currently seeking a Safety Administrator
  •  Molycorp Minerals is hiring a Safety Specialist who specializes in MSHA training to work at our new chemical processing plant
  •  Seeking Oil & Gas clients with requirements for Process Engineer professionals to work either on Permanent or Contract basis in the UK
  •  Seeking Oil & Gas clients with requirements for Safety Engineer professionals to work either on Permanent or Contract basis in the UK
  •  Principal Consultant - CFD specialist - London

Safety and Health Tip 

WISER for Android 

National Library of Medicine at NIH


Civilian Fire Fatalities 

On August 31, 2011, 2 residential fire fatalities were reported by news media throughout the United States.


Safety Recalls

Petzl America Recalls Belay Devices Due to Fall Hazard


Pacific Cycle Recalls Swing Sets Due to Fall Hazard; Sold Exclusively at Toys R Us


CPSC and USFA Warn About Deadly Dangers That Can Linger After Hurricane Irene Passes


Fiskars Brands Recalls SmartPower String Trimmers Due to Burn, Fire and Laceration Hazards


Target Expands Recall of Step Stools with Storage Due to Fall Hazard


Vehicles Recalls  


Tires Recalls 


Child Safety Seat Recalls 


EHS Events 

2011 Georgia Safety, Health and Environmental Conference  

September 6-9, 2011 

Savannah, GA


PureSafety User Conference

Sept. 13-16, 2011

Nashville, TN

Click To Register Today 


NJ ASSE Summer PDC  

September 14, 2011 

Sayreville, NJ


Joint OSHA, LCCA, Abbott Safety Day

Sept. 22, 2011


Waukegan, IL

Topic is Subpart CC


Mary Kay O'Connor Process Safety Center International Symposium 

October 25-27, 2011 

College Station, TX 


If you have a conference or an outing for your safety organization, let me now and I can help spread the message.  And yes, posting is FREE! 

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Process Safety Management

Enforcement Trends and Best Practices

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