My postings back in January were so popular I decided to put the data into EXCEL spreadsheets so that you all can play with the data as you see fit.  I only did PSM (1910.119), Permit-Required Confined Spaces (1910.146), and Control of Hazardous Energy (LOTO 1910.147).  Each workbook contains three (3) worksheets: 1) By # of Citations, 2) # of Inspections, and 3) By Penalty $.  ALL files are in .xlsx format.  Here are the XCEL files...

LOTO 2015

Process Safety Management 2015

Permit-Required Confined Spaces 2015

Results of a recently completed 2015 NIOSH study confirm the necessity of the current Occupational Safety and Health Administration (OSHA) respirator fit testing requirement, both annually and when physical changes have occurred. The study’s conclusions emphasize that respirator users who have lost more than 20 pounds should be re-tested to be sure that the current size and model of respirator in use still properly fits. For over three years, NIOSH researchers followed a cohort of 229 subjects measuring N95 filtering facepiece respirator (FFR) fit and physical characteristics (e.g., face size, weight) every six (6) months.

A few weeks back I posted a OSHRC decision where an OSHA citation for not treating the CNC doors as guards was upheld.  Since then I have received numerous e-mails and a few phone calls telling me I am crazy, as if it was my decision.  Then last week the Video of the Week was a series of video's showing failures within a CNC machine and how a closed door would have helped protect the operator.  Now, with perfect timing, OSHA again issues citations after a worker, 36, died after he became entangled in the machine's operating spindle, as he hand-polished a 40-inch long metal cylinder.  He suffered injuries that led to his death two days later.  He had worked at the plant for two years.  

A fire extinguisher is often times looked upon as a safety device and therefore many overlook these devices potential hazards.  It is true, they can save lives, but they can also take lives and limbs as was the case in this accident.  Back in February, as I reported in the Incident Alerts, two workers were severely injured when a fire extinguisher shell was being used as an air receiver, of which had NO RELIEF VALVE.  This happened at a fire protection company.  The shell catastrophically failed when they were pressurizing it and the accident claimed BOTH legs of a 35-year-old worker and one leg below the knew of a 23-year-old worker.  OSHA has issued their citations...

This case is significant in a number of ways:  1) manufacturer of the equipment put warning signs on their machines pointing out the hazard(s), 2) manufacturer considered the "doors" on their CNC mills and lathes to be "guards", 3) manufacturer installed interlocks on the "doors" (i.e. guards), 4) company bought the machines "used" and many of the interlocks were not operational at the time of purchase, 5) one machine did have a functioning interlock, which was bypassed by tying back it's arm, 6) The VP of the company and the most senior operator felt the machines were safe, 7) neither of these two employees had any training in machine guarding or safety, 8) the company had been cited for machine guarding years earlier and had a serious injury on these machines.  OSHA began their inspection based on an employee complaint and issued a willful citation for unguarded CNC lathes and mills.  OSHA said the "doors" were guards, based on the manufacturer's operation manual, manufacturer's labels on the machines making reference to them as "guards" and the presence of the interlocks on the doors.  The OSHRC agreed and upheld the citation as willful and the full amount.  Here is the arguments the company made against OSHA's citations...

This past week I worked with a client who's safety contact is the HR manager and we had several discussions about OSHA's revised recordkeeping requirements and all the recent reporting changes.  One thing I noticed is that ALL MANUFACTURING facilities are considered "high risk" and are on the list of NAICS's number that must report.  So the "list" of high-risk industries is not very specific!  But one thing that is stirring a lot of discussion is OSHA's official position on "post-accident" drug testing.  OSHA stated in the preamble...

 
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I am teaching another 1-Day Course for ASSE

Intro to Process Safety Management.

February 13, 2017 

The Rio, Las Vegas, NV

 

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