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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 settlement sometimes needs a second opinion

FDR Safety

OSHA continues to cite employers aggressively, and at the same time is suggesting and frequently mandating certain types of abatement. If OSHA’s suggestions are reasonable and feasible, obviously that’s the right way to go. Does the suggested or mandated OSHA abatement reduce risk of injury to your employees?

OSHA 120
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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. Enforcement OSHA' We are not.

OSHA 153
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The Myth Of Zero Energy And Its Adverse Impact On Prevention Through Design

FDR Safety

The term “zero energy” is not the same as the control of hazardous energy, and is not found in any OSHA regulations or materials or in U.S. Examples of such impacts are: •impeding efficient and effective equipment designs when tasks (e.g., national consensus standards (e.g.,

Design 156
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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.