Tag: CFR

Q&A: Fall Protection for a Ladder Enclosed in a Cage

Recently, we received the following question from a subscriber: I need to install a 30-foot fixed ladder as a secondary egress point for an underground pump station. There are two intermediary levels where a step-off will be required. What type of fall protection would be required if I enclose the ladder in a cage?

Is it a Hazardous Material?

We ship empty methyl-ethyl ketone (MEK) containers by truck back to the supplier for refill. Must we classify them as Hazardous Material since the empty containers have only residual amount of MEK left in them, or is there an empty container exemption?

What HazMat Placard Does That Package Need?

Yesterday we discussed the relationship between labeling under the Occupational Safety and Health Administration’s (OSHA) Hazard Communication Standard (HazCom) and the U.S. Department of Transportation’s (DOT) labeling requirements. Today we will offer some placarding tips for shipments of DOT-regulated hazardous materials. Quick Review Placards, like labels, are used to graphically communicate a cargo’s hazard. Generally, […]

GHS or DOT—Which Label Should You Use?

What’s the relationship between labeling under the Occupational Safety and Health Administration’s (OSHA) Hazard Communication Standard (HazCom) and the U.S. Department of Transportation’s (DOT) labeling requirements? Which label must you use? Can you use both? Today we will help answer these questions, and tomorrow we will offer some placarding tips for shipments of DOT-regulated hazardous […]

Q&A: Extension Cord Safety

Recently, we received the following question from a subscriber regarding extension cord safety: OSHA recently sent out a Letter of Interpretation explaining their views for extension cords on the manufacturer’s label stating “Do not plug one extension cord into another extension cord during use.” Does “during use” mean while the extension cord is energized? Or […]

Recognition of Tank Gauging Hazards Leads to Increased Liability

As late as 2014, workers who died during tank gauging and other activities that involved opening the thieves’ hatch on oilfield tanks were recorded as resulting from “natural causes.” As a result, surviving family members were not eligible for workers’ compensation benefits. A recent court case out of Colorado could change that. Jim Freemyer, a […]

Protecting Oil and Gas Workers: The Latest Recommendations

In December, 2014, OSHA formed an Alliance with NIOSH and the National Service, Transmission, Exploration & Production Safety (STEPS) Network to identify hazards faced by oil and gas workers, and to make protective recommendations. Earlier this year, the Alliance issued a Tank Hazard Alert aggregating its findings on oilfield hazards and possible solutions. Some of […]

Let’s Talk RAGAGEP and OSHA Enforcement

In December 2013, the Occupational Safety and Health Administration (OSHA) issued a Request for Information to be used in updating its process safety management (PSM) standard. One of the changes under consideration by OSHA was the addition of a definition for recognized and generally accepted good engineering practices (RAGAGEP)—a term that is used, but not […]

What are RAGAGEP? OSHA Defines a Critical PSM Term

In the wake of the Chevron Richmond Refinery fire in 2012, the U.S. Chemical Safety Board, the federal Occupational Safety and Health Administration (OSHA), and state agencies have stepped up their process safety management (PSM) recommendations and enforcement efforts. Federal OSHA had already initiated the Petroleum Refinery Process Safety Management National Emphasis Program (Refinery NEP) […]