Does OSHA have any specific requirements regarding dimensions of gaps between the moving parts (belt or shaft) and the guards? (LOI)
Yes. OSHA's standards at 29 CFR § 1910.212 and 29 CFR § 1910.219 apply to the safeguarding of machines and mechanical power-transmission equipment and require guarding to protect the operator and other employees in the area from hazards such as those created by ingoing nip points, rotating parts, flying chips, and sparks. In regard to the gap dimension between belts and their respective guards, § 1910.219 (e)(1)(i) states:
Please note that the requirements for guarding belts contained in 29 CFR § 1910.219 do NOT apply to the following types of belts when they are operating at two hundred and fifty (250) feet per minute or less: Membership Content
Something to think about when preparing to issue discipline to those closest to the risk
I am a proponent of accountability in safety; however, I also believe that accountability is necessary at all levels of the organization. We tend to be very quick in identifying the ACTIVE failures by those who made the error, mistake, or violation, and a negative consequence was the result (vs. all those times, the outcome was positive). Heck, in today's world, we may even have caught it all on camera for everyone to see. And if that ACTIVE failure was an EXCEPTIONAL violation (vs. a routine or situational violation), then we can consider holding those who performed that act accountable. But why are we so slow to hold managers accountable for their violations of Management System expectations? Examples include failure to certify SOPs, utilizing the MOC tool on changes, "pencil whipping" permits and safety checklists, failure to manage corrective action plans, etc. These failures are called LATENT ORGANIZATIONAL failures, and although they may be farther away from the ACTIVE FAILURES we see in the videos of accidents, they "set the stage" for many of the ACTIVE FAILURES we may eventually see in future videos of accidents. This discrepancy in who we hold accountable for safety can drive a massive wedge between the men and women doing the dirty and dangerous work closest to the risks and management who sets the tone and expectations of how the business (and, more specifically, the daily tasks) will operate. Remember, disciplining workers closest to the risks will never change a culture (or their behaviors), but a culture may never change without proper discipline. This applies to ALL LEVELS of the organization: those closest to the risks and those removed from the risks. EVERYONE plays a role, and therefore, "accountability" needs to be applied at ALL levels that influence the ACTIVE FAILURES. What are the final changes in the Safer Communities by Chemical Accident Prevention (SCCAP) Rule?
Some of the more eye-opening revisions:
Here is a summary of all the new requirements: 2024 DOT ERG is coming!
DOT/PHMSA have compiled the most important changes from ERG2020 to ERG2024, organized by the color of the corresponding section in the guidebook
In addition to the changes listed below, all sections have undergone minor editorial changes for accuracy and consistency. In this edition, DOT/PHMSA has added QR codes to the back cover of the hard copy version of ERG2024, offering quick access to critical incident reporting information for users on the scene of an emergency. If you have already downloaded ERG for iOS or ERG2020 for Android, published by the Pipeline and Hazardous Materials Safety Administration (PHMSA), no action needed! Your app will update automatically to ERG2024. What does a formal SMS do for me?
One of the top questions I get from "cold callers" or those who have joined SAFTENG and have digested my 400+ articles on Safety Management Systems and all their elements is: So, what does an SMS do for me and my facility? The best way to explain this is by an old scatter chart I had done in 1995 by a consulting firm we hired to help us achieve OSHA's VPP STAR level of safety. This and OSHA's PSM standard were my first exposure to a formal and structured SMS approach to managing safety. When the first chart was done, we were in the "compliance stage," where we had the traditional "safety programs" that were "controlled documents," and each control room had its "safety manual," etc. Our programs were solid but individual programs that could stand independently but were not part of a more extensive "risk control" system. There were no metrics on the critical parts of the program(s) and no audit/validation/verification process that each program was functioning as intended and providing the level of safety we assumed it was providing. Management was a bit concerned when the consultants explained that all of these new activities needed to be taking place; however, we already had a lot of "safety activities" going on. They were not sure how we would be able to manage all these additional activities. So the consultants, along with our Statistical Process Control (SPC) Group (before Six Sigma days), worked with the consultants to plot all of our "safety activities." As you can see, we had a lot of safety activities. But were we getting our money's worth? Culturally speaking, we rocked it! We scored high on trust and credibility on all corporate climate surveys regarding safety matters. We probably had 80-85% of the hourly workforce participating in safety activities daily. However, we had plateaued in our injury reduction performance, and this was a cause of concern for our plant management and corporate management. It turned out "culture" can only take you so far in safety; at some point, we need to live within an SMS that builds on four (4) pillars of the safety/risk management: When are High-Vis garments no longer considered High-Vis?
NOTE: I have never managed a facility/workforce where we required Hi-Vis garments, except for Fire Watches and PRCS Entry Attendants, but those requirements were not for the user's safety, so we did not get into all the ANSI requirements for these vests. However, I do equate this Hi-Vis effectiveness concern to what I dealt with regarding Flame Retardant Clothing (FRC) and its continued effectiveness. Just wearing the PPE is NOT all that matters - wearing PPE that will provide the level of protection we expect is KEY to protecting the user. ALL PPE will lose its effectiveness over time, and it is incumbent upon us to establish this time (with a safety margin included) to ensure the PPE can provide the level of protection we intended when specifying the need for said PPE.
I spent last night and this morning assisting with an industrial accident. The facility requires Hi-Vis clothing/vests and specifies they must be TYPE-R ANSI Class 2. I loved that they DEFINED and QUANTIFIED their requirements using an ANSI standard. I looked at the label in my assortment of Hi-Vis PPE and found a vest meeting this requirement. My Safety Helmet is also "Hi-Vis" with reflective stripping, but I got no credit for my HH. For the record, a TYPE-R ANSI Class 2 vest must have at least: Facility Siting - LPG Containers and Flammable Liquid Tanks (OSHA & NFPA)
This is another opportunity for facility sitting to apply specific metrics to the exercise. Just as the distances for Tank Truck and Rail Car Unloading/Loading facilities are intended to protect our bulk storage tanks, this is intended to prevent BLEVE(s) that could impact the above-ground storage tank. (emphasis by me)
SAFTENG members can download the image depicting this requirement
Facility Siting - Tank vehicle and tank car loading and unloading (OSHA & NFPA)
In some cases, we can actually put specific measurements in our "facility siting" analysis. Take, for example, an old but often missed distance between the tank truck/railcar and the closest aboveground tank. (emphasis by me)
Here is what this looks like: SAFTENG Members can download the full image without watermark and the analysis of NFPA 30 as it applies to these requirements... Line Break gone bad (fluorocarbon)
At 7:30 p.m. on July 2, 2021, Employee #1, Employee #2, and Employee #3 performed two maintenance tasks in the M2 crude rectification section on the ground and second levels at tower M2-T250 and vessel V-207. On July 2, 2021, during the night shift, three (3) gas monomer chemical operators were exposed to toxic fluorocarbons and other hazardous chemicals while performing the maintenance tasks at M2-T250, which resulted in delayed respiratory failure. When returning T250 to normal operations, three employees were exposed to unknown and known acute toxic chemicals, due to inadequate safe work practices and respiratory protection, identified as expected to be in the process streams such as, but not limited to: Do OSHA citations change management's behavior (ABC Model)?
We often refer to the ABC Model when discussing "Behavior Based Safety." ABC stands for Antecedent ⇒ Behavior ⇒ Consequence
So, an OSHA citation could be considered a "consequence" (i.e., a Latent Organizational Failure) of failing to meet OSHA minimum standard(s). So I ask... Do OSHA citations change management's behavior? Overfill of vapor recovery units (UK's HSE Alert)
A Health and Safety Executive (HSE) investigation into a gasoline overfill of a carbon adsorption vapor recovery unit (VRU) revealed concerns with the VRU's design. The overfill prevention system was NOT INDEPENDENT of the basic process control system (BPCS). When the BPCS failed, the overfill prevention system also failed. This resulted in loss of containment, and risked a significant fire and explosion, as well as extensive environmental damage. |
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