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...

Holy cow batman, have we really come to this in the safety profession?!?!?!  An apprentice is crushed to death while standing inside (or technically under) a "machine" looking at some fans he was going to be working on, while the facility technician was performing the LOTO on "the machine".  To get this "machine" to the zero energy state, the technician had to release counter weights (e.g. release stored energy) which in turn killed the apprentice who happen to be standing under one of the counter weights when the energy was released.  The ALJ found that since the contractor was intending to work on "the fans" inside/under "the machine" and since the apprentice was not killed by the fans he was inspecting at the time, that LOTO did not apply to the contractor being inside/under "the machine" and vacated the citation.  The decision made it to the full commission review and the commission was split in their position so it defaulted back to the ALJ's decision and the citation was vacated.  How anyone could come to the conclusion that 1910.147 did not apply here is just amazing!  Here is the case info - LESSON to be learned... Legal does equate to something being SAFE!  I have posted BOTH decisions from the two commissioners, which one do you think was right?

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Intro to Process Safety Management.

February 13, 2017 

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