“Representation not only reflects, but actually changes reality.” — Angela Chen OSHA has several regulations that allow or require employee participation in activities regarding workplace safety. For instance, there is employee participation during OSHA inspections and in the development of the elements of the Process Safety Management (PSM) standard. And those regulations don’t stop at [...]
“Meetings should have as few people as possible, but all the right people.” — Charles W. Scharf Ever been in a Process Hazard Analysis (PHA) meeting where there were over a dozen people? Wasn’t it excruciating? Either you wondered why you needed to be there, or you wondered why some of the other people needed [...]
“OSHA has determined that…the Form 300A data are sufficient for enforcement targeting and compliance assistance at this time.” — OSHA in 84 FR 392, 25-Jan-2019 Many have a hard time distinguishing between an injury that is OSHA “recordable” and an injury that is OSHA “reportable”. “Recordable” means that an employer must complete a Form 301 [...]
“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 [...]
“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 [...]
“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, [...]
“The entire health care system is now being organized around machines instead of human beings. Not prioritized to reduce human suffering, but rather to optimize a computerized recordkeeping system. This is a tragedy.” — Carolyn Jourdan Imagine for a moment that you are a new PSM coordinator. The person who had the job before you [...]
