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OSHRC decisions on Machine Specific LOTO Procedures, LOTO Periodic Inspections, and LOTO Training for Affected/Other employees
Safety Info Posts - OSHA Compliance Posts
Written by Bryan Haywood   
Thursday, 20 November 2014 14:46

These LOTO decisions by the OSHRC are HUGE in establishing some "minimums" for LOTO procedures, periodic inspections, and training for "affected" and "other" employees.  Readers should pay very close attention to the details that OSHA used in their arguments of how poorly "machine specific procedures" were written (missing data, conflicting data, no magnitudes listed, etc.).  The facility really wasted the courts time with their arguments (my professional opinion) as OSHA had their ducks in a row AND the facility made it easy for OSHA... i.e. plenty of low hanging fruit for OSHA to pick from within their LOTO program!!!  Here are the LOTO decisions:

NOTE: this case also involved a machine guarding decision that can be seen in the full decision.

Last Updated on Thursday, 20 November 2014 15:18
 
EPA RMP Citations @ Cold Storage Facility (NH3; $124K)
Safety Info Posts - PSM and RMP Citations/Analysis
Written by Bryan Haywood   
Wednesday, 19 November 2014 22:10

Respondent owns and operates a controlled-temperature storage warehouse for food products. The Facility is located adjacent to Interstate 91 and east of the Quinnipiac River, within a mile of numerous shops and business and approximately 1 mile from several schools. Respondent uses anhydrous ammonia in a refrigeration "process".  In 2009, Respondent filed a Program 3 RMP for the Process and reported that it used 22,600 pounds of anhydrous ammonia. Respondent's most recent RMP re-submission, in 2013, again reported that one Program 3 process uses 22,600 pounds of ammonia. Accordingly, the Process is a "covered process" subject to the provisions of Part 68 because Respondent "uses," "stores," and "handles" the RMP chemical anhydrous ammonia at the Facility in an amount greater than 10,000 pounds. According to Respondent's RMP, there are public receptors within the distance to the endpoint for a worst case release of the amount of anhydrous ammonia used in the Process. Likewise, modeling performed by EPA indicates that the endpoint for a worst case release from each Process is greater than the distance to a public receptor. Additionally, the Process is subject to OSHA's PSM requirements at 29 C.F.R. § 1910.119 because it uses anhydrous ammonia in an amount over the threshold quantity of 10,000 pounds. Therefore, in accordance with 40 C.F.R. § 68.10(a}-(d), Respondent's use, storage, and handling of anhydrous ammonia in its Process is subject to the requirements of RMP Program 3. On October 18, 2012, EPA inspectors visited the Facility ("Inspection") to assess Respondent's compliance with Section 112(r) of the CAA and with Sections 302-312 of the Emergency Planning and Community Right-to-Know Act.  Here is a breakdown of the citations:

Last Updated on Wednesday, 19 November 2014 22:26
 
39 incidents & 0 updates (11/19/14)
Safety Info Posts - Incident Alerts
Written by Bryan Haywood   
Wednesday, 19 November 2014 20:42
 
OSHA's First Aid and BBP training requirements
Safety Info Posts - Emergency Response
Written by Bryan Haywood   
Tuesday, 18 November 2014 10:38

A very common question we get during our work is... "Am I required to have a first aid team on site?" And "If I am, do they fall under the Blood Borne Pathogen standard"?  OSHA actually provided us some great insight into their position on these questions in a 2007 LOI.  They stated...

 
OSHRC upholds WILFULL GDC with Postal Carrier Fatality due to Heat Stroke
Safety Info Posts - OSHA Compliance Posts
Written by Bryan Haywood   
Friday, 14 November 2014 19:50

WOW... you want to read a case from !@#$, this will be some interesting reading for you.  If there was ever a case where the lesson is "Do as you say you're going to do in your safety program" this case is the "poster child" for that cause.  Too many strikes against the management at the USPS to list so I am just going to provide the link to the case, but this is without a doubt one of the best investigated cases in the history of OSHA!  To get a Willful on the General Duty Clause is tough, but they nailed this one and there are plenty of learning's for everyone in this case.  CLICK HERE for the case file.

 
OSHRC determines that a zip tie does NOT constitutes a “permanent” fixture
Safety Info Posts - OSHA Compliance Posts
Written by Bryan Haywood   
Friday, 14 November 2014 19:24

This case makes two (2) decisions that on the surface appear to be a step backwards - but readers should not read anything into these decisions!  The refrigerator in the power strip was lost merely because the CSHO did NOT document the power pull the refrigerator was putting on the power strip.  So before we go thinking that we can plug our refrigerators into power strips SAFELY or use zip ties to fasten our power stips to the building - think TWICE.

Complainant alleged a serious violation of the Act in Citation 1, Item 2 as follows:

29 CFR 1910.303(b)(2): Listed or labeled electrical equipment was not used or installed in accordance with instructions included in the listing or labeling:
a) Kitchen area: On June 3, 2013 and at times prior, employees were exposed to fire and shock hazards from overloading a relocatable power tap used to energize a “True Manufacturing” food preparation table/refrigerator. Relocatable power taps are only listed to be used for low ampere devices such as computers and their peripherals.

Last Updated on Friday, 14 November 2014 19:50
 
2014 Photo of the Week #47 (PSM Facility Siting)
Safety Info Posts - Photo of the Week
Written by Bryan Haywood   
Friday, 14 November 2014 15:36

facility siting critical pipingOSHA/EPA is still issuing Facility Siting citations, just this week there was one issued, for facility not including a FS analysis as part of their process hazard(s) analysis.  This weeks photo shows the result of a common findings from our FS Analyzes. Critical equipment along roadways MUST be protected from vehicle impact - it does not get any SIMPLER than this!  So the next time someone claims a vehicle would never damage unprotected piping along a roadway, just remember this weeks Photo of the Week.

Last Updated on Friday, 14 November 2014 15:52
 
Testing for water in your Ammonia Refrigeration Process
Safety Info Posts - Chemical Process Safety (PSM/RMP)
Written by Bryan Haywood   
Friday, 14 November 2014 11:47

cold-flo sample drawingA while back I was participating in a PHA of a refrigeration process and somehow the discussion led to one that sort of scared me a bit... collecting a liquid ammonia sample to test for water content.  The actual art of ammonia refrigeration not being my areas of expertise, I had always reserved Bulletin No. 108. Guidelines for Water Contamination in Ammonia Refrigeration Systems for a rainy day reading project (which never came by the way).  I focused more on the process safety related items and thought water contamination was merely a production/energy issue and therefore no safety/health risks.  That was MY IGNORANCE and now I am kicking myself in the ass for missing this task in previous PHA/JHA’s and Audits.  But having asked around of many of my friends and clients in the refrigeration industry I have come to realize that I may not be the only ignorant ass safety professional when it comes to catching liquid ammonia samples!  Here are my questions and concerns with the task...

Last Updated on Monday, 17 November 2014 16:42
 
2014 Video of the Week #47 (Demolition Safety w/ Miley Cyrus)
Safety Info Posts - Video of the Week
Written by Bryan Haywood   
Friday, 14 November 2014 00:00

I know I will catch a lot of flak for this one, but it did make me smile after a crazy week.  WARNING!  This video contains the Miley Cyrus music video which contains some scenes that may be offensive to some and may not be safe for work, but these three construction guys are hillarious in this SPOOF of her outlandish video!  We all need to take a minute and smile at the end of a long day/week!  You may need to be a true full fledge safety geek to see the humor in this video though.

Last Updated on Friday, 14 November 2014 15:51
 
OSHA HAZWOPER Citations @ manufacturer of plastic thermoformed products (HAZWOPER, PPE & HAZCOM; $49K)
Safety Info Posts - Emergency Response
Written by Bryan Haywood   
Thursday, 13 November 2014 12:47

Workers cleaning a chemical spill at a manufacturer of plastic thermoformed products had not been trained in proper cleanup procedures or provided proper personal protective equipment, according to an OSHA investigation. OSHA found that workers experienced symptoms of overexposure to an isocyanates chemical used in plastics manufacturing that can cause occupational asthma and other lung problems, as well as irritation of the eyes, nose, throat and skin. Seven serious violations, carrying proposed penalties of $49,000, were cited. OSHA initiated the inspection on Sept. 5, 2014, under the National Emphasis Program for Occupational Exposure to Isocyanates*, after it received a complaint that alleged improper cleanup of a spill of approximately 100 gallons of the chemical diphenylmethane diisocyanate, a type of isocyanate. OSHA cited the company for seven serious violations for lack of a hazardous materials spill response plan and failure to train workers on how to respond to spills. Additionally, required personal protective equipment, such as gloves and respirators, was not provided. Here is a breakdown of the citations:

 
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