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Assessing Feasibility

FDR Safety

This blog complements past blogs and my most recent blog about the OSHRC overturning OSHA citations regarding LOTO on Matsu presses. The answers can be determined but only after documented due diligence using Task Based Risk Assessment (past blogs) and assessing feasibility of hazard controls.

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What to Do When LOTO is Not Feasible

FDR Safety

I’m finding clients who have excellent lockout/tagout programs but who have not taken the necessary step of identifying tasks where LOTO is not feasible. From a compliance standpoint, OSHA can cite you. Your only recourse is to prove LOTO is not feasible. Document why power is needed and LOTO is not feasible.

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Are You Ready For An OSHA Audit?

FDR Safety

OSHA sees great opportunity because your industry does realize finger injuries and amputations that are not realized in other companies where operators have automation and/or engineered safeguards to protect the point of operation. The post Are You Ready For An OSHA Audit? All of these production issues are part of your reality.

OSHA 149
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OSHA citing maintenance equipment violations despite low risk

FDR Safety

Many of you may be wondering why, all of a sudden, OSHA is spending an inordinate amount of time inspecting the machines and equipment in plant maintenance areas. However, if you recently experienced OSHA’s increased focus in this area, you may wish you had read this sooner. Document your findings. We are not.

OSHA 153
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Is Gravity Part of OSHA’s LOTO Regulation?

FDR Safety

Where do gravity related accidents fall in the eyes of OSHA? In some cases OSHA is involved and in others, there is a civil suit alleging tort liability. In the OSHA cases, the Agency might suggest that gravity is a hazardous energy to be controlled. As part of your documented training, remind them… GRAVITY WINS.

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A Wake-up Message for Employers or An Ounce of Prevention…

FDR Safety

In too many situations, an employee was injured and OSHA stepped in with significant fines for violations of 29 CFR 1910.147. I’m proud of our record in helping clients litigate citations/violations and/or fulfill obligations under informal or formal OSHA settlement agreements. 2 at OSHA, former VP of Safety and Health at AK Steel.

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Is Gravity Part of OSHA’s LOTO Regulation?

FDR Safety

Where do gravity related accidents fall in the eyes of OSHA? In some cases OSHA is involved and in others, there is a civil suit alleging tort liability. In the OSHA cases, the Agency might suggest that gravity is a hazardous energy to be controlled. As part of your documented training, remind them… GRAVITY WINS.