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NST/Engineers, Inc. Offers
World Class Training.

Training Offered by NST/Engineers, Inc.
HAZCOMM Training by NST/Engineers, Inc.

HAZCOMM Training is required by law for anyone who works with "materials". YOU must know the hazards of any "materials" with which you work!

These materials include: paints, varnishes, resins, solvents, laboratory chemicals, adhesives, cleaning compounds and thousands more... just about any "material" you can imagine!

This Training has been mandatory since the early 1980's pursuant to the Occupational Safety and Health Administration's (OSHA's) regulation 29 CFR 1910.1200, the "Hazard Communication Standard" also known informally as the "Right to Know" law. OSHA has NEVER documented full compliance with this law, predominantly because new hires are not properly trained. OSHA has compliance oversight.

Accidents, injuries, legal judgments and fines resulting from non-compliance and the subsequent mishandling of hazardous materials costs business, industry, and academia many millions of dollars annually. The human toll is staggering!


WHAT: HAZCOMM (OSHA's HAZard COMMunication standard) training.

WHERE: On-Site or, for larger classes, a site mutually acceptable to our clients and NST/Engineers, Inc.

COST: $150.00. (To arrange for any training class, please call (302) 239-2700.)

Training will include learning:
· Lessons from incidents involving deaths and injuries in business, industry and academia.
· The common safety hazards involved in the handling of common materials.
· How to acquire, read and implement the precautions listed in materials' Material Safety Data Sheet (MSDS) for almost any "material".
· How to protect yourself and coworkers by understanding the safety implications of the information in the MSDS.
· The proper signage, labeling and safety requirements for containers and hazardous materials storage areas.

Participants completing the 4 Hour Course will receive a HAZCOMM course completion certificate from NST/Engineers, Inc.


NST/Engineers, Inc. also offers
expert OSHA 40 Hour HAZWOPER Training and the 8 Hour "Refresher" Course

(HAZardous Waste OPerations and Emergency Response)

If you or your employees want to do any work involving hazardous wastes, you know that, before starting, you need OSHA 40 Hour HAZWOPER Certification. Then, each year, you must obtain recertification via the 8 Hour "Refresher" Course.

Prepare now by earning your certification, or recertification, from an NST/Engineers’ expert trainer. He will share 30 years of hands-on and supervisory hazardous waste management experience gained at The Philadelphia Naval Shipyard, NST/Engineers, and DuPont. He is Lead Author of the Manual and Desk Reference.

He has trained and certified thousands with backgrounds ranging from site cleanup workers to engineers and managers. Why not you or your employees?

 Certificates are awarded upon satisfactory completion of the course.

The course is based on the authors' 100 years of combined experience with hazardous materials. See the book reference on our Home Page

Course fee for all 5 days is only $595.00.

Questions Email c_l_hackman@msn.com

For a fee-based consultation call with a Licensed Professional Engineer between 3:00pm and 5:00pm Eastern Daylight Time, call (302) 239-2700.

For information at any time on our Hazardous Waste Operations and Emergency Response (HAZWOPER) and other safety training, click here.

Syllabus for OSHA 1910.120(e) Hazardous Waste Operations & Emergency Response - "HAZWOPER" 40-Hour Worker Course

This course provides managers, supervisors, operators and laborers who regularly participate in on-site hazardous substance removal or other activities, which expose, or have the potential to expose personnel to hazardous substances and health hazards.

This comprehensive training is needed to work safely at OSHA regulated hazardous waste sites. Topics to be covered include: hazard recognition, site characterization, atmospheric monitoring, personal protective equipment, waste handling, containers, labeling and placarding, emergency response activities, decontamination, and spill control and containment.

This course consists of lecture, multi-media, and hands on segments. Students will be required to demonstrate the skills learned in the classroom.

This course meets and exceeds the training requirements of OSHA 29CFR1910.120.

The text for the course is "Hazardous Waste Operations & Emergency Response, Manual and Desk Reference" © 2002 McGraw-Hill. Trainees requesting respirator fit testing are required to bring their own respirators.


Day One:
Registration and Introduction 0.25 hours
Regulators, Legislation, and the HAZWOPER Working Environment 1.0
Hazardous Waste Defined (OSHA, DOT & EPA) 1.0
Break 0.25
Material Hazards (corrosive, toxic, fire and explosive, reactive, and radioactive) 1.0
Introduction to the NIOSH Pocket Guide and Emergency Response Guidebook 0.5

Lunch 1.0

Chemical Incompatibility 1.0
Toxicology (What makes us sick? Routes of entry-inhalation, ingestion, 0.5
absorption, and injection; acute versus chronic exposures; body systems and chemical effects thereon)

Break 0.25

Toxicology (Continued) 1.0
Review 0.25
8.0 hours

Day Two:

, Review, and Q&A 0.25 hours
Personal Protective Equipment (the respiratory system, types and uses of respirators) 2.0

BREAK 0.25

PPE Continued (Chemical Protective Clothing and eye, head, hand, foot, and hearing protection) 1.0
Classroom exercise-Selecting the proper level of Respiratory Equipment 0.5


Classroom exercise-Selecting the proper level of CPC 0.5
Decontamination (Routine and emergency, safety showers, eyewash stations, proper procedures, housekeeping) 1.0

BREAK 0.25

Signs, Labels, Placards, and Other Identification (Introduction to containers - drums, IBCs, tanks, tankers, and railcars) 1.0
Review 0.25 hours
8.0 hours

Day Three:

Sign-in, Review, and Q&A 0.25 hours Material Safety Data Sheets and International Chemical Safety Cards 2.0

BREAK 0.25

Confined Spaces (Permit Required versus Non-Permit) 2.0


Other Workplace Hazards (Accidents and their causes, pro-active safety, 1.0 kinetic, mechanical, thermal, electrical, acoustical, hypothermia and hyperthermia, cuts and punctures, burns, and Lock-Out/Tag/Out


0.25 Sampling and Monitoring (Personal versus area, O2, LEL/LFL, CO, H2S,1.0 Organic and Inorganic acids, and NH4. Monitors, meters, colormetric tubes, badges, and lab sampling) Hands-on exercise with plant meters

Review 0.25 hours
8.0 Hours

Day 4:

Sign-in, Review, and Q&A 0.25 hours Hazardous Waste Generators (Pollution Prevention - P2, waste 1.0 Minimization and elementary neutralization; packaging, handling, storage, and shipment of drums and other containers) Emergency Response (Responsibilities and duties of the various levels, 1.0 the Incident Command System and the Unified Command Structure, incidental versus emergency response releases; spill control, containment, and cleanup; layout of work zones and the activities performed therein)

BREAK 0.25

The Site Specific Health and Safety Program (Health and Safety Plan, Emergency Response Plan, medical surveillance, Emergency Action Plan)1.0


Hands On Exercises (PPE, MSDS, CPC, Incident)2.0 hours

BREAK 0.25 hours

Hands On Exercises (PPE, MSDS, CPC, Incident cont'd)1.0 hours Review 0.25 hours
8.0 Hours

Day 5:

Sign-in, Review, and Q&A 0.25 hours Hands-on Exercise (Donning, working in, and doffing of Level A or B PPE.) 1.0
Site Control1.0

BREAK 0.25

Hands On Exercises (PPE, MSDS, CPC, Incident) 1.0


Classroom Exercise-What if…? (Emergency response tabletop)1.0
Independent study (During which photos of all students will be taken for wallet cards) 0.5
Final Review (Last chance for questions) 1.0
Exam and Grading 1.0
Review of Exam (Final feedback and questions) 0.5
8.0 hours


Safety Index Offers Recommendations on Preventing Job-Site Accidents to Reduce Human and Financial Costs of these Injuries

Liberty Mutual Group, the country's leading provider of workers compensation insurance, products and services, today announced findings from their first-annual Liberty Mutual Workplace Safety Index, listing the 10 leading causes of injuries and illness that account for 86 percent of the $38.7 billion in wage and medical payments employers paid in 1998, the last year for which data is available.

The Safety Index highlights these leading causes and also provides guidelines to help reduce the human and economic costs generated by the top causes of job-site accidents. Liberty Mutual identified the leading causes of workplace injuries and illness and associated direct cost using its own claims data and findings from the Bureau of Labor Statistics and the National Academy of Social Insurance. According to the Safety Index, overexertion, falls and being struck by an object are among the leading causes of workplace accidents. When the indirect cost of workers compensation claims are added to the $38.7 billion in direct costs identified by the report, the total economic burden of workplace injuries and illness is far greater, with estimates ranging between $125 billion to $155 billion.

"There is a clear link between workplace safety and a company's performance," explained Gary Gregg, executive vice president of Liberty Mutual's Commercial Markets, which provides commercial insurance coverage to large and medium size companies. "Our Safety Index can help focus existing safety programs on those areas that have the greatest potential negative impact on employees and employers." Gregg noted three benefits from improved workplace safety.

First, it reduces employee pain and suffering.

Second, it helps avoid the direct cost of workplace injuries - such as wage replacement payments and medical care expenses.

Third, it prevents the indirect cost of these accidents - lower employee morale, lost productivity and the cost of hiring or training overtime or temporary replacement workers. Liberty Mutual will release its annual ranking each year, based on the most recent data from the federal Bureau of Labor Statistics and the National Academy of Social Insurance. Accidents leading to workplace injuries and illness that resulted in employees missing five or more days of work in 1998, include:

Accident causes and workers compensation direct cost paid in 1998. Estimated workers compensation direct cost nationwide:

Overexertion - injuries caused by excessive lifting, pushing, pulling, holding, carrying or throwing of an object, 25.57%, cost$9.8 billion.

Falls on same level, 11.46%, and $4.4 billion

Bodily reaction - injuries resulting from bending, climbing, loss of balance and slipping without falling, 9.35% and $3.6 billion.

Falls to lower level, such as falling from a ladder or over a railing, 9.33% and $3.6 billion.

Being struck by an object, such as a tool falling on a worker from above, 8.94%, and $3.4 billion

Repetitive motion, 6.10%, and $2.3 billion.

Highway accidents, 5.46%, and $2.1 billion.

Being struck against an object, such as a carpenter walking into a door frame 4.92%,and $1.9 billion.

Becoming caught in or compressed by equipment, 4.176%, and $1.6 billion.

Contact with temperature extremes that result in such injuries as heat exhaustion, frost bite or burns, 0.92%, and $.3 billion.

Total for all accident causes: (100.00%), and $38.7 billion.

Still think you don't need safety training?

Training Update Do you have personnel that operate Powered Industrial Trucks, more commonly known as "forktrucks", at your facility? Are they Trained Operators? Is your business in an industry other than agricultural?

One year ago, OSHA’s Final Rule on the operator training standards went into effect. Operators hired before December 1, 1999 must be trained to safely operate your forktrucks. This training must be documented and refreshed annually.

Operators hired nowmust be trained to safely operate your forktrucks prior to being assigned to such duty.

  Click here if you require assistance in obtaining qualified on-site training for the operators at your facility.

  Click here to download OSHA’s Powered Industrial Truck Operator Training; Final Rule. ---------


Below is a partial list of training conducted by NST/Engineers, Inc. staff:

"Facility Manager Environmental Awareness Training for Clean Air Act"

"Underground Storage Tank Regulatory Compliance" for Naval personnel at the Naval Undersea Warfare Center 

"CAA and UST Regulatory Compliance" for the Certified Hazardous Materials Manager Examination Review Course 

"Technical and Legal Issues Concerning Superfund" 

"Environmental Issues Affecting Real-Estate: Underground Storage Tank Regulations"  

"Technical Issues, and Federal and State Requirements for Underground Storage Tanks"  

"Regulatory Overview, and Issues Affecting Data Quality in Environmental Samples"  

"Role of Geology during Preparation of Environmental Risk Assessments"  

"OSHA 29CFR1910.146 Confined Spaces" 

"OSHA 29CFR1910.178 Powered Industrial Trucks (Forklift) Operation" 

"OSHA 29CFR1910.120(e) Hazardous Waste Operations & Emergency Response (HAZWOPER)" 

"OSHA 29CFR1910.132, 133, 134, 136, and 137 Personal Protective Equipment"  

"OSHA 29CFR1910.147 Lock Out/Tag Out" 

"OSHA 29CFR1910.134 Respiratory Protection" 

"OSHA 29CFR1926.1101 Asbestos Abatement Workers and Supervisors" 

"AHERA (40 CFR763)/ASHERA Asbestos Building Inspector/Management Planner" 

"Red Cross Burn Treatment" 

"EPA/HUD Lead Abatement" 

"New Jersey Lead Worker" 

"ASTM 1527 & 1528 Phase I Environmental Site Assessment and Transaction Screen Analysis" 

"Underground Storage Tank Systems" 
We also established and led over 250 sessions of a corporate in-house continuing education program ("Air Products University")


Here is an example of a seminar offered to non-technical groups:

Asbestos, Lead, and Radon in Real Property


I. Asbestos

  A.History of "The Miracle Mineral"

  B.Regulatory Overview

  C.Known Health Effects

  D.Uses and Applications in Residential and Commercial Properties

  E.Sampling and Analysis

  F.Methods of Abatement
    a) By Resident Homeowner (CAUTION)
    b) By Licensed Abatement Contractor
   2)Encapsulation and Enclosure Management Plan-Commercial
   3)Advantages and Disadvantages of Each Method



  B.Regulatory Overview

  C.Known Health Effects
   1)Children 0-6 years vs Adults

  D.Uses and Applications in Residential and Commercial Properties
   1)Lead Based Paint
   2)Plumbing (Plumbum is Latin for Lead)
    a) Pipes and Solder
   3)Special Commercial, i.e., X-ray Facilities

  E.Sampling and Analysis
   1)Lead Based Paint 
    a) X-ray Fluorescence (XRF)
    b) Lead-check Pens
    c) Certified Lab Analysis "National Lead Laboratory Accreditation Program (NLLAP)"
    a) 1 Liter Sample-First Draw/5 minute/15 minute
    b) Samples to Certified Lab

    a) By Resident Homeowner (CAUTION)
    b) Abatement Contractor Training Regulations
    c) MANDATORY in the Case of Childhood Lead Poisoning
  4)Advantages and Disadvantages of Each Choice


  A.Naturally Occurring
   1)Formed by Deterioration of Radioactive minerals
   2)"Radon Daughters"
   3)Defined as a Gas

  B.Health Effects

  C.Geographical Considerations- "Reading Prong"

  D.Construction Types Prone to Contamination
   1)Routes of Entry into Structure

  E.Testing and Analysis
   1)Do-It-Yourself Kits/Short Term vs Long Term Monitoring
    2)"Real Time" Monitoring

  F.Abatement Design and Installation

For a fee-based consultation call with a Licensed Professional Engineer between 3:00pm and 5:00pm Eastern Daylight Time, call (302) 239-2700.

For information at any time on our Hazardous Waste Operations and Emergency Response (HAZWOPER) and other safety training, click here.

Some recent incidents that occurred are summarized below. Proper training and reasonable safety management practices would have prevented injury and death!

EASTERN U.S. FOOD WAREHOUSE CITED BY OSHA FOR ALLEGED WILLFUL SAFETY VIOLATIONS; $109,500 IN PENALTIES PROPOSED OSHA cited the firm, and proposed penalties of $109,500 against it for two alleged willful violations, four alleged repeat violations, and nine alleged serious violations of OSHA standards.

The action results from a six month investigation that focused on workplaces with higher-than-average rates of injuries or illnesses.

OSHA alleges that the company willfully violated OSHA's powered industrial truck standard by not training employees in the safe operation of forklift trucks and not evaluating or certifying their ability to operate them safely. The willful violations carry a proposed penalty of $55,000.

OSHA charged the firm with four alleged repeat violations, carrying a total proposed penalty of $30,500, for:
1. permitting access to fire extinguishers to be blocked,
2. failing to mark routes to exits,
3. failing to properly wrap and stack stored material, and
4. failing to provide training in the hazardous materials in the workplace.

A repeat violation is one for which an employer has been previously cited for the same or a substantially similar condition and the citation has become a final order of the Occupational Safety and Health Review Commission. The company was previously cited for these conditions at other locations in April, 1999.

The alleged serious violations for which the employer was cited included:
 failure to mark doors "not an exit" as required;
 improper installation of an exit door;
 blocking an aisle with loaded pallets;
 dismounting and leaving unattended a fork-lift truck with the load in the raised position;
 failing to inspect industrial powered trucks before placing into operation;
 failing to provide properly operating emergency eye-wash facilities.

The serious violations carry a total proposed penalty of $24,000.

A willful violation is defined by OSHA as one committed with an intentional disregard for, or plain indifference to, the requirements of the OSHA act and regulations.

A serious violation is defined as a condition which exists where there is a substantial possibility that death or serious physical harm can result.


The citations resulted from a worker inside an oven being crushed, and dying a few days later from the injuries. As a result of inspection following that incident, OSHA cited the company for 33 alleged serious and five alleged willful workplace safety and health violations.

A worker was cleaning the inside of a paper coater oven, requiring the hood to be open. The OSHA required Lockout/Tagout procedures were not followed. Another worker accidentally actuated the control that closed the hood of the oven when reaching across the control panel. The worker inside the oven was crushed and died a few days later.

The alleged willful violations related to violations of the confined space standard as well as violations of the Lockout/Tagout Standard.

The alleged serious violations involved: fall protection, flammable liquids, personal protective equipment, respiratory protection, confined space entry requirements, first aid, forklift training, overhead crane operation, other lockout/tagout requirements, machine guarding, electrical hazards, bloodborne pathogen standard, and the hazard communication standard.

(Lock-Out/Tag-Out and Confined Spaces-Engulfment)

The citations covered four willful and five serious after a worker suffocated inside a sand silo. The proposed penalties totaled $201,500.

A safety inspection was conducted after OSHA learned of a fatality in December 1999. In that accident, an employee suffocated by being engulfed with sand while working inside a sand silo that was accidentally placed in operation.

Four citations for alleged willful violations were issued to the firm, two for confined space and two for Lockout/Tagout procedures. The employer had comprehensive written programs for the confined space standard and the lockout standard but failed to implement them.

Five citations for alleged serious violations were issued for machine guarding, hook maintenance, electrical standards, and working surfaces.

One citation for an alleged other-than-serious violation was issued for chain slings which lacked identification. The slings did not have a required tag which indicated the rated size, grade and capacity.


OSHA has cited the contractor for 15 alleged safety and health violations and proposed penalties of $49,600.
The alleged violations were discovered during an unprogrammed inspection which began February when framers/plasterers were working on unsafe, inadequately-constructed, scaffolding with no fall protection. OSHA’s standards require that fall protection be provided for employees working on a scaffold over 10 feet in height.

The company was cited for eight serious violations, and seven repeat violations, including two that had been cited twice previously.

Some of the eight serious violations included:
* the employees not being protected by protective helmets while working in areas where there was a possible danger of head injury from falling objects;
* no fire extinguishers being available on-site;
* the scaffold platforms were not at least 18 inches wide;
* each scaffolding platform did not extend over the centerline of its support by at least 6 inches;
* each scaffold over 10 feet was not equipped with a guardrail system;
* employees had not received scaffolding training;
* employees were not wearing fall protection when working on a roof over 6 feet;
* employees had not received fall protection training;
* and scaffolds were not erected, moved, dismantled, or altered only under the supervision and direction of a competent, qualified, person.

The seven repeat violations included:
* the employer not maintaining an inspection program conducted by a competent person that examined job sites, materials and equipment on a frequent and regular basis;
* the platforms on working levels of the scaffolds were not fully planked or decked between the front upright and the guardrail supports (cited twice previously);
* unstable objects were used to support scaffolds and platform units;
* access ladders were not provided to and used by employees (cited twice previously);
* scaffolding and scaffolding components were not inspected by a competent person for visible defects before each work shift;
* and guardrail systems were not installed on the ends of platforms.

Employers and employees with questions regarding workplace safety and health standards can call the nearest OSHA office. OSHA’s toll-free hotline may be used to report workplace accidents, fatalities, or situations posing imminent danger to workers. The number is 1-800-321-6742.


The alleged violations were discovered during a complaint inspection. The company was cited for 31 serious items consisting of 53 violations of OSHA standards, one repeat, and four other-than-serious safety violations.

Within the serious category, violations included:
* failing to implement a periodic and regular inspection of injection molding equipment;
* guarding of floor and wall openings;
* defective fixed and portable stairs;
* inadequate emergency action plan;
* confined space standard;
* lack of training in the use of fire extinguishers;
* certificate of proof testing of chain slings; machine guarding;
* unguarded power transmission devices;
* unsafe electrical systems;
* exposure of energized electrical parts;
* electrical grounding;
* lack of personal protection equipment for employees exposed to methylene chloride;
deficiencies of the Hazard Communications Program;
and * failure to train and inform employees as required by the methylene chloride standard.

The four other-than-serious violations were for:
*the lack of respirator protections, emergency eye wash, * inspection records for steel slings, and * the improper adjustment of guards on an abrasive grinder.

An other-than-serious violation is one where a violation has a direct relationship to job safety and health but is not serious in nature.

The one repeat violation was failing to list and label electrical equipment.

A repeat violation is one in which the employer has been cited, during the past three years, for substantially similar infractions of the law.

Partial safety and health inspections were conducted as a result of a formal complaint from union representatives. The company employs approximately 450 workers at the Birmingham site. The inspections covered a coke plant and a slag wool plant.

They are high hazard areas of the company’s operation.
During OSHA's inspection of this plant, a broad range of safety and health hazards were found. OSHA has cited this employer in the past.

OSHA's safety inspection resulted in 20 serious citations with a total proposed penalty of $66,500 and three repeat violations with proposed penalties of $45,000.

Among the serious hazards, the company was cited for * having removed the deadman switches from the hot cars.

These switches automatically turn off power in an emergency situation.

Other serious violations concerned:
 * lack of complete fall protection while cleaning the slag wool roof area;
 * hazards in connection with lockout/tagout standards which require that machinery be rendered inoperable during maintenance and repair;
 * unguarded floor holes;
 * defective mobile work platforms;
 * defective exit signs;
 * flammable/combustible storage hazards;
 * lack of training in the use of fire fighting equipment;
 * failure to prohibit smoking in hazardous areas;
 * electrical hazards, and
 * hazards involving aisles and passageways, abrasive grinders, sprocket wheels and chains, and compressed air.

Electrical hazards and the absence of a guard rail to protect workers from a 25-foot fall hazard at the coal dump accounted for the repeat safety violations.

Twelve additional serious citations resulted from the health portion of OSHA's inspection. Six of these dealt with exposure to coke oven emissions which can be a carcinogenic hazard. Others concerned:
* emergency eyewash where sulfuric acid is in use;
* blood borne pathogen training, and hepatitis B vaccine,
* confined space hazards,
* and hazard communications training where carbon monoxide is present.

Also cited among the serious health hazards was * the company practice of driving a front-end loader across hot slag rather than picking up the slag with a bucket and backing out of the pit trailing the load.
OSHA stated that driving across hot slag exposes a front-end loader operator to fire hazards and obstructed vision due to steam. The company had already experienced several fires at this plant and a fatality had resulted in 1999 at another subsidiary of the company.

Employees working in an area where hot cars are in use are placed at risk. The removal of deadman switches from the hot cars exposed these employees to being struck by, or run over by, the equipment.


A contract employee was assigned to sandblast the inside of a reactor vessel during turnaround activities at a petrochemical refinery. Instead of relying on the contract company's own air compressors in accordance with the contractor's policy, the contract foreman connected the employee's supplied air respirator to a hose containing what he thought was plant air.

Instead it was nitrogen!br>

Both hoses were identical except for markings at the shutoff valve.
The sandblaster entered the vessel, descended to the bottom, placed the respirator hood on his head and was overcome.

1. Employers must instruct employees to recognize and avoid unsafe conditions associated with their work (29 CFR 1926.21(b)(2)).
2. Contractors should follow a policy of using only their own air compressors or breathing air cylinders for their employees.
3. Middle and/or upper management personnel should routinely check first line supervisors to insure they are following established company safety policies.


An employee sitting in a looped chain was lowered approximately 17 feet into a 21-foot deep manhole. Twenty seconds later he started gasping for air and fell from the chain seat face down into the accumulated water at the bottom of the manhole. An autopsy determined oxygen deficiency as the cause of death.

1. Instruct employees to recognize and avoid unsafe conditions associated with their work environment (29 CFR 1926.21(b)(2)).
2. Instruction employees on hazards involved in entering confined or enclosed spaces (29 CFR 1926.21(b)(6)(i) and (b)(6)(ii)).
3. Provide and require employees to use appropriate respiratory protection (29 CFR 1926.103(a)(1) and 1910.134.

Two employees were welding brackets onto an oil storage tank (55,000 gallons). The tank, half full, contained explosive atmospheres of vapor from waste chemical and oil materials from automobile and truck service stations. One worker was killed and another injured when the tank exploded and the top was blown off.


1. The employer must instruct each employee in the recognition and avoidance of unsafe conditions and the regulations applicable to his work environment "to control or eliminate any hazards [29 CFR 1926.21(b)(2)].

2. The employer is responsible for requiring the wearing of appropriate personal protective equipment in all operations where there is an exposure to hazardous conditions [29 CFR 1926.28(a)]. In this case, safety belts and lanyards or other means of fall protection would have prevented employees from falling off the tank to the ground. Also, fire or heat resistant safety clothing should have been provided and used.

3. Welding, cutting, or heating must not be done where the application of flammable paints, or the presence of other flammable compounds, or heavy dust concentrations creates a hazard [29 CFR 1926.352(c)].

4. Drums, containers, or hollow structures which have contained toxic or flammable substances must be filled with water or cleaned of such substances and ventilated and tested before welding, cutting, or heating is undertaken on them [29 CFR 1926.352(i)].


Three employees were sandblasting portions of a heat exchanger in a manufacturing plant, preparing the surface for paint. The job was almost finished except for some touch-up work. The air compressor used to supply breathing air to the sand-blasters' hoods was sent to another job. The workers hooked their supply hoses into the plant's air system without clearing it with the plant's management.

The plant operators, not knowing the plant air was being used for breathing air, shut down the compressor for scheduled maintenance. This caused the nitrogen back-up system to come on line to maintain air pressure. One sandblaster was asphyxiated from the nitrogen being fed into his hood.


The employer must:
1. Ensure that employees are thoroughly trained when required to use respirators in atmospheres immediately dangerous to life, in accordance with 29 Code of Federal Regulations (CFR) 1926.103(c)(1).
2. Ensure that the compressor used to supply breathing air has a high-temperature or carbon monoxide alarm or both, in accordance with 29 CFR 1926.103(f).

3. WARNING: Nitrogen back-up systems are often used as the back-up system for compressed air (or plant utility air) systems. Always determine the type of back-up system before using any air system for breathing purposes.

4. Ensure that frequent and regular inspections of the job site are being done, in accordance with 29 CFR 1926.20(b)(2). Ensure that employees are trained in hazard recognition and avoidance, in accordance with 29 CFR 1926.21(b)(2).