Recordable vs. Reportable: OSHA’s Changing Requirements

“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 [...]

By |2023-08-11T18:22:31-05:00July 20th, 2023|Current Events, Process Safety Management|Comments Off on Recordable vs. Reportable: OSHA’s Changing Requirements

OSHA’s New Dust NEP: What is the Impact on DHAs?

“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 [...]

By |2023-02-09T16:34:03-06:00February 9th, 2023|Combustible Dust, Current Events|Comments Off on OSHA’s New Dust NEP: What is the Impact on DHAs?

Preventing Profit Over Safety: OSHA’s New Reliance on Penalties

“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 [...]

By |2023-02-02T15:41:50-06:00February 2nd, 2023|Current Events, Process Safety, Workplace Safety|Comments Off on Preventing Profit Over Safety: OSHA’s New Reliance on Penalties

Just Right: Hazardous (Classified) Locations

“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 [...]

By |2023-01-26T16:45:23-06:00January 26th, 2023|Chemicals, Combustible Dust, Process Safety|Comments Off on Just Right: Hazardous (Classified) Locations

Exhaust Ducts: When Safeguards Have Their Own Hazards

“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 [...]

By |2023-01-19T16:56:25-06:00January 19th, 2023|Process Safety, Workplace Safety|Comments Off on Exhaust Ducts: When Safeguards Have Their Own Hazards

Avoiding the Streetlight Effect: How Does the CPI Really Get Safer?

“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 [...]

By |2023-01-05T15:25:30-06:00January 5th, 2023|Process Safety, Process Safety Management, Workplace Safety|Comments Off on Avoiding the Streetlight Effect: How Does the CPI Really Get Safer?

Process Safety: Tornadoes in December

“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, [...]

By |2022-12-16T00:06:38-06:00December 16th, 2022|Current Events, Procedures, Training, Workplace Safety|Comments Off on Process Safety: Tornadoes in December

PSM Documents: How Long Do I Have to Keep This Stuff?

“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 [...]

By |2022-12-01T17:42:35-06:00December 1st, 2022|Process Safety, Process Safety Management|Comments Off on PSM Documents: How Long Do I Have to Keep This Stuff?

The Good Old Days: Never Again

“Nostalgia is a file that removes the rough edges from the good old days.”  — Doug Larson It’s hard to imagine the New York skyline without the Statue of Liberty. The Paris skyline without the Eiffel Tower. The San Francisco skyline without the Golden Gate Bridge. The Saint Louis skyline without the Gateway Arch. But [...]

By |2022-11-03T15:06:31-05:00November 3rd, 2022|Workplace Safety|1 Comment

Is There a Season of Death? Work-Related Fatalities

“For everything there is a season, and a time for every purpose under heaven. A time to be born and a time to die, a time to plant, and a time to harvest.”  — Ecclesiastes 3:1-2 When October rolls around and plans for Halloween are being made, thoughts often turn to autumn as a time [...]

By |2022-10-27T15:11:51-05:00October 27th, 2022|Workplace Safety|Comments Off on Is There a Season of Death? Work-Related Fatalities
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