“There is nothing that this age, from whatever standpoint we survey it, needs more, physically, intellectually, and morally, than thorough ventilation.” — John Ruskin I worked on a project once that required me to spend a lot of time in the control building. It was a substantial building with a kitchen and breakroom, several offices, [...]
“People just don’t sue doctors they really like.” — Alice Burkin, plaintiff’s attorney Nice doctors get sued less. On the other hand, “evil corporations” are far more likely to be sued for their mistakes, or as lawyers describe it, their “negligence.” And in the consciousness of many Americans, there are few corporations more categorically evil [...]
“I will show you fear in a handful of dust.” — T.S. Elliot OSHA does not have a combustible dust regulation. Instead, it relies on a hodge-podge of regulations combined with the General Duty Clause. If someone wants to understand what OSHA expects in terms of combustible dusts, they must turn to OSHA’s Combustible Dust [...]
“OSHA has issued new enforcement guidance to make its penalties more effective in stopping employers from repeatedly exposing workers to life-threatening hazards or failing to comply with certain workplace safety and health requirements.” — Department of Labor press release, January 26, 2023 There are two common complaints about OSHA citations and fines after a fatal [...]
“My life experience confirms that the U.S. government frequently overclassifies data.” — Michael Hayden When it comes hazardous (classified) locations—electrical classification—even seemingly sophisticated technical facilities often get it wrong. The issue isn’t with the class, or the group, but with the division. Getting the division wrong, though, can render a facility more hazardous than it should [...]
“The guard shall be such that it does not offer an accident hazard in itself.” — 29 CFR 1910.212(a)(2) Machine guarding It’s hard to imagine any safeguard that doesn’t pose its own burden. Safety shoes are heavy and make a worker less nimble. Side shields on safety glasses impair peripheral vision. Interlocks introduce the prospect [...]
“You can have data without information, but you cannot have information without data.” — Daniel Keys Moran Last summer, we talked about the Chemical Safety Board’s compilation of incident data since their reporting rule became effective in March 2020. Companies experiencing catastrophic releases that result in one or more fatalities, one or more in-patient hospitalizations, [...]
“The battle of getting better is never ending.” — Antonio Brown There’s an old joke about someone looking for their keys under a streetlight. A passerby offered to help but after a while, asked, “Are you sure this is where you lost them?” “No, I lost them over there in the park.” “Then why are [...]
“It’s often said that the definition of insanity is doing the same thing over and over and expecting a different result. Very, very, very often said.” – Daniel D’Addorio The end of one year and the beginning of a new year is often a time of reflection and planning. Reflection on what we did right [...]
“The potential changes to particular provisions of the current PSM standard that OSHA is considering include: 8. Clarifying paragraph (e) to require consideration of natural disasters and extreme temperatures in their PSM programs, in Response to E.O. 13990.” — OSHA, 20-Sep-2022 call for Stakeholder comments I grew up in the Midwest. I’ve lived in Joplin, [...]
