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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. During my career in engineering and safety, I have observed thousands of machine setups and other tasks where LOTO is simply not possible.

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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. Many, if not most safety courses, are designed for administrative issues of compliance. We can help.

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Good Safety Signage

FDR Safety

There are good safety signs, bad safety signs and those that don’t tell you anything. An example of a “bad safety sign” is shown to the right. The FDR TaBRA process includes determination of feasible risk reduction for the specific machine and task. Below is my idea of a good safety sign.

Safety 120
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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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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. For more advice on safety, please call us at (615) 628-8746.

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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.