OSHA updates enforcement policy on process safety management

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Photo: kodda/iStockphoto

Washington — OSHA has updated its process safety management enforcement policy for the first time in 30 years.

The agency announced the change in a directive that went into effect Jan. 26. The directive is intended for OSHA inspectors and other personnel, but also provides insight to employers and workers covered under the standard.

Much of the document is in a question-and-answer format, covering subjects such as:

  • Process hazard analysis
  • Operating procedures
  • Training
  • Incident investigations
  • Emergency planning and response
  • Compliance audits

Appendix A in the document is intended to clarify some parts of OSHA’s standard on PSM. Appendix B includes links to letters of interpretation, which formed the basis for the Q&A. Appendix C contains an index of common terms and phrases.

“OSHA promulgated the PSM standard in 1992 in response to the numerous catastrophic chemical manufacturing incidents that occurred worldwide,” the directive states. “Since the promulgation of the standard, numerous questions have been submitted and compliance guidance provided to industry on the application of the standard.”

State plans must notify OSHA of their intent to adopt the directive within 60 days. Otherwise, they must have policies and procedures that are “identical to or different from the federal program.” Either way, state plan adoption must occur within six months.


McCraren Compliance offers a full range of safety and health training and consulting services. Plus we can help you incorporate well-being into your traditional systems in order to support the Total Worker Health of your workforce.

Call 888-758-4757, email info@mccrarencompliance.com or visit our website www.mccrarencompliance.com

Original article published by Safety+Health an NSC publication

‘Incredibly destructive’: CSB publishes report on fatal dust explosion

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Photo: Chemical Safety Board

Washington — Hazards related to combustible dust “must be controlled beyond the existing regulatory requirements,” says the Chemical Safety Board, which renewed its call for OSHA to begin rulemaking on a general industry standard.

CSB addresses the issue in a recently released final report on a fatal May 2017 explosion and fire at the Didion Milling dry corn mill in Cambria, WI. Five workers were killed and 14 were injured.

CSB investigators found that the company neglected to develop and implement a written program on combustible grain dust, and failed to install venting or suppression on a dust filter collector to prevent an explosion. However, the agency notes that Didion Milling wasn’t required to enact various safety management systems because OSHA lacks an overarching general industry standard for combustible dust.

CSB recommends that an OSHA standard address hazard recognition, dust hazard analysis, incident investigation, engineering controls, operating procedures, process safety information and training.

Other recommendations:

  • Employers should ensure pneumatic transport and dust collection ductwork is designed to maintain a minimum transport velocity.
  • Engineering controls such as detection, suppression, isolation, venting and pressure containment should be used during the design of dust safety systems.
  • Employers should review fire and building codes to determine the type of construction and evaluate additional requirements based on the materials being handled.
  • Employers should ensure the standards applied are applicable and appropriate to hazards inside the facility.
  • Employers should consider abnormal and upset conditions when assessing personal protective equipment.

“Combustible dust explosions and fires can be deadly and incredibly destructive,” CSB Chair Steve Owens said in a press release. “The terrible tragedy at Didion was made even worse due to the lack of important safeguards in the design of the mill equipment and the lack of engineering controls at the facility that could have reduced the potential for serious fires and explosions.”


McCraren Compliance offers a full range of safety and health training and consulting services. Plus we can help you incorporate well-being into your traditional systems in order to support the Total Worker Health of your workforce.

Call 888-758-4757, email info@mccrarencompliance.com or visit our website www.mccrarencompliance.com

Original article published by Safety+Health an NSC publication

Fall Protection again leads OSHA’s annual ‘Top 10’ list of most frequently cited standards

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New Orleans — For the 13th consecutive fiscal year, Fall Protection – General Requirements is OSHA’s most frequently cited standard, the agency and Safety+Health announced Tuesday during the 2023 NSC Safety Congress & Expo.

Eric Harbin, administrator of OSHA’s Dallas-based Region 6, presented the preliminary list, which represents OSHA Information System data from Oct. 1, 2022, to Sept. 29. S+H Associate Editor Kevin Druley moderated the session.

The standards that comprise the Top 10 remained unchanged from FY 2022, with some movement within their ranking. Respiratory Protection, which ranked fourth in FY 2022, fell three spots to seventh. Powered Industrial Trucks rose two spots to round out the top five, which also featured Hazard Communication, Ladders and Scaffolding.

The list:

  1. Fall Protection – General Requirements (1926.501): 7,271 violations
  2. Hazard Communication (1910.1200): 3,213
  3. Ladders (1926.1053): 2,978
  4. Scaffolding (1926.451): 2,859
  5. Powered Industrial Trucks (1910.178): 2,561
  6. Lockout/Tagout (1910.147): 2,554
  7. Respiratory Protection (1910.134): 2,481
  8. Fall Protection – Training Requirements (1926.503): 2,112
  9. Personal Protective and Lifesaving Equipment – Eye and Face Protection (1926.102): 2,074
  10. Machine Guarding (1910.212): 1,644

“Although incredible advancements are made in safety each year, we continue to see many of the same types of violations appear on OSHA’s Top 10 list,” NSC President and CEO Lorraine M. Martin said. “As a safety community, we must come together to acknowledge these persistent trends and identify solutions to better protect workers.”

Finalized data, along with additional details and exclusive content, will be published in the December issue of S+H.

The presentation included a remembrance for Patrick Kapust, the late former deputy director of OSHA’s Directorate of Enforcement Programs. Kapust, who presented Top 10 data at Congress & Expo from 2011 to 2022, died in April. He was 56.


McCraren Compliance offers a full range of safety and health training and consulting services. Plus we can help you incorporate well-being into your traditional systems in order to support the Total Worker Health of your workforce.

Call 888-758-4757, email info@mccrarencompliance.com or visit our website www.mccrarencompliance.com

Original article published by Safety+Health an NSC publication

OSHA proposal to update hazcom standard under White House review

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Photo: ArtboyAnimation/iStockphoto

Washington — An update to OSHA’s standard on hazard communication is undergoing a final review, according to the White House Office of Information and Regulatory Affairs website.

The final rule was sent to OIRA on Oct. 11. It’s unknown how long the office will take to complete the review – one of the final steps in the regulatory process.

OSHA is seeking to align the hazcom standard (1910.1200) to the seventh revision of the Globally Harmonized System of Classification and Labeling of Chemicals, also known as GHS. The current standard is linked to the third revision of GHS, an update that occurred in 2012.

January 2021 slideshow details OSHA’s proposed changes, which include:

  • Additional clarification of existing regulatory requirements.
  • Incorporating new hazard classes and categories.
  • Improving and streamlining precautionary statements.
  • Increased alignment with other countries, helping facilitate international trade.

Some of the proposed changes cover Appendices A-D. Appendix A would have revised health hazard definitions, including updated chapters on skin corrosion/irritation and serious eye damage/eye irritation.

OSHA notes that, in Appendix B, the flammable gases category 1 “was extremely broad” and essentially covered all flammable gases. In some instances, that led to employers choosing chemicals with higher risks.

Pyrophoric and unstable gases would be placed under category 1A, under the final rule. Appendix B also is expected to include a new chapter on desensitized explosives and “better differentiation between aerosols and gases under pressure.”

In the final rule, Appendix C could contain updated guidance and precautionary statement clarifications on aerosols, desensitized explosives and flammable gases.

Changes to two sections in Appendix D, on Safety Data Sheets, are proposed. Section 9 (physical and chemical properties) would include particle size, and Section 11 would include interactive effects and the use of “SAR/QSAR/read across.”

The final rule may also potentially fix issues with release for shipment, small packages labeling and SDS preparation.

“OSHA expects the HCS update will increase worker protections and reduce the incidence of chemical-related occupational illnesses and injuries by further improving the information on the labels and Safety Data Sheets for hazardous chemicals,” the agency stated when it issued the proposed rule in February 2021. “Proposed modifications will also address issues since implementation of the 2012 standard and improve alignment with other federal agencies and Canada.”


McCraren Compliance offers a full range of safety and health training and consulting services. Plus we can help you incorporate well-being into your traditional systems in order to support the Total Worker Health of your workforce.

Call 888-758-4757, email info@mccrarencompliance.com or visit our website www.mccrarencompliance.com

Original article published by Safety+Health an NSC publication

Chemical Safety Board calls for changes to OSHA’s PSM standard

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Photo: Chemical Safety Board

Washington — OSHA should amend its guidance on the control of reactive hazards element of its standard on process safety management of highly hazardous chemicals (1910.119), the Chemical Safety Board says.

CSB makes 15 recommendations, while outlining additional concerns, in a recently released final report on a deadly December 2020 chemical explosion at the Optima Belle facility in Belle, WV. One worker died after the explosion of a dryer that was removing water from the compound. The blast also led to serious property damage and a shelter-in-place order for the surrounding community.

According to the report, the dryer was over-pressurized in part because facility management “did not adequately understand the potential for, analyze the hazards of, or detect and mitigate the self-accelerating thermal decomposition reaction.” In addition, the company for which the facility was producing the chemical didn’t transmit sufficient PSM data to Optima Belle, and both organizations had “ineffective” PSM systems.

CSB renewed its call for OSHA to “broaden” the PSM standard “to cover reactive hazards resulting from process-specific conditions and combinations of chemicals,” as well as hazards from self-reactive chemicals.

The report details six safety lessons for the industry:

  • Don’t rely solely on chemical hazard information from Safety Data Sheets when using the chemical at elevated temperatures or pressures, or with other temperatures with which the chemical could react. Information can vary significantly between suppliers. Be prepared to perform additional hazard analyses or to seek additional publicly available information.
  • Ensure chemical hazard information identified from previous incidents, studies, and lab tests are maintained and organized in a manner that will allow workers to be aware of the information and its appropriate use.
  • Be aware of the multiple tools capable of identifying whether a chemical has thermal or reactive hazards that could trigger a process safety incident.
  • Make sure hazards involving new processes are controlled by evaluating process safety information on involved chemicals, examining the laboratory and pilot-scale process, and consult site safety and process engineering personnel to determine if the process can be safely conducted at the tolling facility at full production scale with existing equipment.
  • Create and maintain a robust safety management system to prevent reactive chemical incidents.
  • Know that outsourcing the production or processing of a hazardous material doesn’t outsource the responsibility for process safety.

McCraren Compliance offers a full range of safety and health training and consulting services. Plus we can help you incorporate well-being into your traditional systems in order to support the Total Worker Health of your workforce.

Call 888-758-4757, email info@mccrarencompliance.com or visit our website www.mccrarencompliance.com

Original article published by Safety+Health an NSC publication

Lockout/Tagout update now “long-term” action in latest regulatory agenda

Original article published by Safety+Health
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Photo property of OSHA

Washington — A planned update to OSHA’s Lockout/Tagout standard (1910.147) has been pushed to “long-term actions” under the Department of Labor’s Spring 2023 regulatory agenda.

The move is one of a handful of changes in the latest agenda, published June 14 by the White House Office of Information and Regulatory Affairs.

OSHA lists an August 2024 target date for a notice of proposed rulemaking regarding the Lockout/Tagout update, but those dates are often tentative. The updated rule is expected to incorporate technological advances in the control of hazardous energy.

The agency also pushed its rule on Shipyard Fall Protection (1915.71) to “long-term actions,” with an NPRM expected no earlier than November 2024.

OSHA currently has two final rules under OIRA review – one of the final stages in the rulemaking process. One rule, Occupational Exposure to COVID-19 in Health Care Settings (1910.501), has been under review since Dec. 7.

The other, under review since April 7, is a revised rule on injury and illness data submission (1904.41). The agency seeks to require establishments with 100 or more employees in high-hazard industries to annually submit injury and illness data from the more detailed Forms 300 and 301, in addition to Form 300A. Establishments in those same industries with 20 to 99 employees would need to submit only Form 300A. In addition, OSHA would end the electronic reporting requirement for establishments with 250 or more employees that aren’t on the list of high-hazard industries. The agency also would update its classification system that determines which industries are covered under its electronic reporting requirements, as well as require establishments to include a company name when submitting data to the agency.

OSHA issued one final rule in the past six months, one concerning whistleblower provisions under the Taxpayer First Act of 2019, which went into effect in March. The agency also issued an interim final rule in February on whistleblower provisions under the Criminal Antitrust Anti-Retaliation Act of 2019.

The agency rescinded its proposed rule to revoke Arizona State Plan status in February.


McCraren Compliance offers many opportunities in safety training to help circumvent accidents. Please take a moment to visit our calendar of classes to see what we can do to help your safety measures from training to consulting.

Public Citizen calls for an OSHA heat standard

Washington — An OSHA standard aimed at protecting workers from extreme heat exposure could prevent at least 50,000 injuries and illnesses annually, a watchdog group contends.

Original article published by Safety+Health
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Photo: OSHA

recent report from Public Citizen also claims that workplace heat exposure or stress is linked to as many as 2,000 worker deaths and 170,000 injuries each year.

Other findings in the report:

  • Heat stress-related tragedies “disproportionately strike” low-income workers and workers of color.
  • Latino workers are three times more likely to suffer a heat-related death than non-Latino workers.
  • Agricultural workers experience heat stress-related deaths at a rate 35 times higher than the rest of the workforce.
  • Workplace injuries rise by 1% for every 1° C increase in temperature.

Public Citizen is calling on OSHA to develop a standard to protect indoor and outdoor workers from heat. The agency published an advance notice of proposed rulemaking in the Oct. 27, 2021, Federal Register. The public comment period expired in early 2022.

In April of that year, OSHA introduced a National Emphasis Program on heat-related inspections. The NEP, set to remain in effect until April 2025, includes plans to conduct inspections in more than 70 “high-risk” industries when the heat index reaches 80° F or higher.

“Each year without an OSHA heat stress standard puts the health and lives of more workers on the line,” the report states. “The risk of workplace heat stress illness, injury and death is increasing with climate change, and predictions for extreme temperatures and increased heat waves in 2023 and 2024 make the need for a heat standard more urgent than ever.”

In a press release, Public Citizen worker health and safety advocate Juley Fulcher adds: “Employers can take simple actions to protect their employees, but unfortunately many see it as a burden. By implementing a binding and comprehensive heat stress standard from OSHA, we can prevent countless illnesses, injuries, and fatalities and create safer, more productive workplaces.”


McCraren Compliance offers many opportunities in safety training to help circumvent accidents. Please take a moment to visit our calendar of classes to see what we can do to help your safety measures from training to consulting.

Choose the right fall protection training partner

Original article published by Safety+Health

Who needs fall protection training? How often should it occur? Who can best conduct it, and does one size fit all?

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Photo: Diversified Fall Protection

Responding is Kevin Kelpe, brand manager, Diversified Fall Protection, Westlake, OH.

In 2017, OSHA made sweeping updates to its standards on walking-working surfaces in general industry and personal fall protection systems (1910.140). Although the changes in the final rule affect manufacturers, employers and workers in many ways, some of the most important changes pertain to training and other fall protection services. Although these services are more expertise than equipment, they can best be provided by a fall protection integrator with practical experience designing and installing systems, and not an all-purpose training company. Not all training is created equal (even if it’s technically compliant).

OSHA’s 1910.30 standard requires employers to train employees on fall hazards and fall protection equipment, and to retrain these employees at regular intervals. Employers in general industry are also required to designate authorized, competent and qualified persons (three separate designations in the rule) who use, supervise the use of and install fall protection systems, respectively. And that’s not all! The rule now requires that anchorage connectors used for travel restraint, fall arrest and suspended access be inspected, tested, certified and recertified at varying intervals (1910.27 and 1910.140). The updated rule requires documentation produced during these activities to be maintained by building owners and made available for contractors who work on their properties.

Whew! Considering all of this, it’s easy to see why a company offering just one element of fall safety may not cut it. The most appropriate partner for employers would, first, have broad experience with eliminating hazards. They would then have hands-on experience designing solutions using their own products and those of other manufacturers, and experience installing and certifying those integrated systems. Employers should seek out an organization with many regional locations that put the required personnel in their backyard – a regional team of engineers, inspectors and trusted advisors to demystify compliance and give employers peace of mind. Employers also capture economies of scale if they can use the same provider for the equipment and all of the services required by law (to be clear, that’s training, inspection, testing and certification).

The 2021 Fall Experience Survey developed by the American Society of Safety Professionals further illuminated the employer’s need for access to deeper expertise. Survey respondents cited a lack of planning as the leading cause of falls. Also among the top 10 causes were a lack of training and competency programs. ASSP found that, in many cases, building owners had installed fall protection systems, but those systems were inappropriate for the circumstances in which the work was done. Or, in other cases, workers used connectors that were incompatible with the equipment installed and were injured even though they were trained and tied off, albeit improperly.

This may seem surprising, but it’s understandable; in recent years, many products promising more efficient compliance have become available. The market has responded to new regulation with lots of rapidly evolving technology. Indeed, we may be in the golden age of fall safety.

Paradoxically, however, this influx of options may be widening the gap between workers and safety for a time, as the market catches up to match employers with newly minted experts. This further emphasizes the need for a true partnership. A transactional relationship between providers and employers is no longer a suitable option to protect workers or businesses. Employers now, more than ever, require subject matter experts in fall safety. They require fall protection partnership for life.


McCraren Compliance offers many opportunities in safety training to help circumvent accidents. Please take a moment to visit our calendar of classes to see what we can do to help your safety measures from training to consulting.

OSHA extends comment period on proposal to amend rules on workplace lead exposure

First published by Safety+Health an NSC publication

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Washington — In response to multiple stakeholder requests, OSHA has extended until Oct. 28 the comment period on a proposed rule that would revise the agency’s standards on occupational exposure to lead in general industry and construction.

According to a notice published in the Aug. 18 Federal Register, the extension provides stakeholders additional time to collect information and data necessary to submit responses and comments. The initial deadline was Aug. 29.

OSHA, in the June 28 Federal Register, published an advance notice of supplemental proposed rulemaking seeking input on blood lead levels for medical removal and return to work, as well as:

  • Medical surveillance provisions, including triggers and frequency of blood lead monitoring
  • Permissible exposure limits
  • Ancillary provisions for personal protective equipment, housekeeping, hygiene and training

The agency’s blood lead level for medical removal is 60 micrograms per deciliter or more for general industry and 50 micrograms per deciliter or more in construction. The return-to-work BLL is less than 40 micrograms per deciliter.

OSHA adopted its standards on lead exposure for general industry and construction in 1978 and 1992, respectively. Since then, studies by the American Conference of Governmental Industrial Hygienists, the Environmental Protection Agency, and the Association of Occupational and Environmental Clinics, among other organizations, have indicated that adverse effects can occur at lower BLLs.

“For example, BLLs as low as 5 μg/dL have been associated with impaired kidney and reproductive function, high blood pressure, and cognitive effects attributed to prenatal exposure,” the ANPRM stated. “Poorer performance on neurocognitive and neuropsychologic assessments were observed in adults with BLLs as low as 5-19 μg/dL compared with adults with BLLs below 5 μg/dL.”


McCraren Compliance assists employers in protecting their workers, starting with a comprehensive Work-site Analysis, Hazard Prevention, Controls, and Safety & Health Training.

Please contact us today at 888-758-4757 to learn how we can provide mine safety training and consulting for your business.

HazCom standard update coming before year’s end? Spring 2022 regulatory agenda released

First published by Safety+Health an NSC publication

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Photo: Office of Information and Regulatory Affairs

Washington — An update to OSHA’s Hazard Communication standard could happen as soon as December, according to the Department of Labor’s Spring 2022 regulatory agenda.

Published June 21, the agenda – issued by the Office of Information and Regulatory Affairs twice a year – provides the status of and projected dates for all potential regulations listed in three stages: pre-rule, proposed rule and final rule.

In this latest regulatory agenda, the HazCom standard update was moved from the proposed rule stage to the final rule stage.

OSHA’s current Hazard Communication standard (1910.1200) is linked with the third edition of the Globally Harmonized System of Classification and Labeling of Chemicals, also known as GHS. In February 2021, OSHA issued a proposed rule to update the regulations to align with GHS’ seventh edition.

Also listed in the final rule stage is a permanent COVID-19 standard for the health care industry. That’s expected to appear sometime in the fall, OSHA administrator Doug Parker and Labor Secretary Marty Walsh indicated in separate Congressional hearings in the past four weeks.

OSHA’s Infectious Diseases standard, meanwhile, is listed in the proposed rule stage, with a notice of proposed rulemaking slated for May at the earliest.

OSHA’s Emergency Response standard moved from the prerule to the proposed rule stage, and a notice of proposed rulemaking is not expected to appear until at least May as well. That regulation will attempt to “address the full range of hazards or concerns currently facing emergency responders, and other workers providing skilled support,” and provide performance specifications for protective clothing and equipment.

Meanwhile, the agency is reopening the rulemaking record on clarifying parts of its Walking-Working Surfaces standard. The agency planned to correct a formatting error in Table D-2 of that regulation and “revise the language of the requirements for stair rail systems to make them clearer and reflect OSHA’s original intent.”

The regulation was in the final rule stage in the Fall 2021 regulatory agenda, released Dec. 10, but is now back to the proposed rule stage.

OSHA’s attempt to revise Table 1 of its silica standard for construction was moved from the proposed rule stage to the list of long-term actions. That means the agency isn’t expected to perform any work on that standard for at least six months.

The Mine Safety and Health Administration had one change from the Fall 2021 regulatory agenda: A final rule requiring written safety programs for mobile equipment and powered haulage at surface mines or “surface areas of underground mines” could appear in October.


McCraren Compliance assists employers in protecting their workers, starting with a comprehensive Work-site Analysis, Hazard Prevention, Controls, and Safety & Health Training.

Please contact us today at 888-758-4757 to learn how we can provide mine safety training and consulting for your business.