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I am proud to announce that SAFTENG and The Chlorine Institute have renewed our partnership for another year (through 2026).  Members of The Chlorine Institute receive a FREE SAFTENG membership.  If you qualify, please contact me

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What is the LOC/MOC in a flammable process?
I grew up using the acronym MOC, but I think it was confusing when PSM came out, since everyone thought MOC meant “Management of Change.” Now I don’t know if that is why they went with LOC (Oxygen Concentration), but that is what is used today. So what is LOC, and why does it matter in flammable liquids and gases processing? … HomeRead More »
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Managing the limitations of the PPE
I’m curious how everyone manages the “service life” of the PPE their facility utilizes? I have written a lot about the care, use, donning/doffing, and inspection of all kinds of PPE. Today let’s talk about the PPE’s limitations in terms of its “service life”, specifically a hard hat. This discussion began on LinkedIn when someone posted an image of the Manufacture...
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EPA recognizes "bollards" as a safeguard
From at least August 20, 2025, until June 12, 2026, Respondent failed to ensure process equipment located in areas accessible to vehicles was protected from heavy machinery by means of bollards, guardrails, or other acceptable forms ofprotection, as required by 40 C.F.R. 68.65(d)(2), which directs owners and operators to ensure that equipment complies with recognized and generally accepted good engineering...
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Does 1910.106(e)(2)(iii) require introduction of fresh air similar to provisions contained in §1910.106(e)(3)(v)(a)?
No. §1910.106(e)(2)(iii) does not require the exclusive use of fresh air for ventilation purposes. Additionally, 1910.106(e)(2)(iii) is a performance requirement and does not explicitly require the introduction of fresh air to meet the performance requirements of the standard. OSHA, under 1910.106(e)(2)(iii), expects employers to provide adequate ventilation to maintain concentrations below 25% of...
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Did your PPE Hazard Assessment consider the use of FRC?
Most of my work as a consultant involves working in flammable liquid and gas process areas. I always wear my FRC if I am inside these areas and there is activity that necessitates I wear my FRC. Where did I get that list of activities? A 2010 OSHA LOI… … HomeRead More »
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Understanding "or" and "nor" in OSHA standards (Flammable Liquids LOI)
Specifically, you asked for clarification on the use of the words “or” and “nor” in the paragraph Design, Construction, and Capacity of Storage Cabinets-Maximum Capacity, 29 CFR 1910.106(d)(3)(i), which states, 1910.106(d)(3)(i) Not more than 60 gallons of Class I or Class II liquids, nor more than 120 gallons of Class III liquids may be stored in a storage cabinet. …...
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If the source container is metal and the receiving container is nonconductive, do the bonding and grounding requirements apply? (OSHA Archived LOI and CPL)
Bonding and grounding two non-conductive containers would seem unnecessary, since non-conductive materials are insulators and therefore cannot conduct current through them. However, static electrical charge can be generated when two dissimilar materials pass quickly by one another (i.e., liquids flowing through pipes, even air). OSHA recognizes that there are many factors that affect the size and strength...
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I asked AI... what is the likelihood of workers building up a long-term tolerance to Bitrex with a once-per-year and 3-5-minute fit test?
The likelihood of a worker building a long-term tolerance to Bitrex (denatonium benzoate) from a single 3-to-5-minute annual respirator fit test is virtually zero. Physiological habituation—where the nervous system stops responding to a stimulus—requires frequent, sustained exposure over time. A brief, once-a-year exposure is nowhere near the threshold required to alter a person’s neurological...
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Does your organization recognize the difference between a Safety Policy, a Safety Program, and a Safe Work Practice?
In this discussion, think about your Respiratory Protection efforts. Does the organization have a Policy on the use of RP? Does the policy statement recognize that RP is the lowest form of protection (e.g., Hierarchy of Controls) and mention that Engineering and Administrative controls will be considered BEFORE the use of RP? We then move to the written program that outlines all the management functions...
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Understanding OSHA's Instance-by-Instance (IBI) policy
Some may agree with this policy, and others may decry government overreach. Nonetheless, the policy is real and carries some serious consequences for really bad employers. Here is a breakdown of the policy and how its being used… … HomeRead More »
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Trends in Permit-Required Confined Space Enforcement
The enforcement climate around 29 CFR 1910.146 remains intensely focused on fundamental programmatic failures rather than isolated technical errors. When companies fail at confined space entry, it is rarely due to a nuance in the standard—it is almost always a total breakdown of core safety controls. Top 5 Citation Areas for 1910.146 … HomeRead More »
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IDLH Visuals for Br, Cl2, NH3
Visual Aid for Teaching PPM and % by Volume
I am always trying to give my students a visual when I begin talking about IDLH values. It’s one thing to say that Chlorine’s IDLH is 10 ppm and explain what that means within the training room. So I have been playing with some AI sources, mainly Google Gemini and ChatGPT, to create visual aids I can add to my training resources, and after several iterations, I came up with this one. STILL...
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