The Severe Violator Enforcement Program (SVEP) directive became effective on June 18.

"Do as I say, not as I do?"

(You wouldn’t know it from the OSHA website, they didn’t  provide either a date or directive number on their “directive.”  But negligence on their part on paperwork isn’t the crime that it is when employers make a paperwork omission…)

According to the  unnumbered, undated Directive posted on the website,   “This new directive establishes procedures and enforcement actions, including mandatory follow-up inspections and inspections of other worksites of the same company where similar hazards or deficiencies may be present. It replaces OSHA’s Enhanced Enforcement Program (EEP).”

“This Instruction establishes enforcement policies and procedures for OSHA’s Severe Violator Enforcement Program (SVEP), which concentrates resources on inspecting employers who have demonstrated indifference to their OSH Act obligations by committing willful, repeated, or failure-to-abate violations. Enforcement actions for severe violator cases include mandatory follow-up inspections, increased company/corporate awareness of OSHA enforcement, corporate-wide agreements, where appropriate, enhanced settlement provisions, and federal court enforcement under Section 11(b) of the OSH Act.”

What can trigger SVEP Status?
 Willful, repeated or failure-to-abate violations in one or more of the following circumstances:
A fatality or catastrophe situation
• Industry operations or processes that expose workers to severe occupational hazards
• Workers exposed to hazards related to the potential releases of highly hazardous chemicals
• Egregious enforcement actions

For our industry,  Falls (General Industry) and Amputations appear to be the primary categories  for awareness.
Here are the appropriate references for Fall Hazards, General Industry:
29 CFR §1910.23 – Guarding floor and wall openings and holes [Walking-Working Surfaces]
29 CFR §1910.28 – Safety requirements for scaffolding [Walking- Working Surfaces]
29 CFR §1910.29 – Manually propelled mobile ladder stands and scaffolds (towers) [Walking-Working Surfaces]
29 CFR §1910.66 – Powered platforms for building maintenance [Powered Platforms, Manlifts, and Vehicle-Mounted Work Platforms]
29 CFR §1910.67 – Vehicle-mounted elevating and rotating work platforms [Powered Platforms, Manlifts, and Vehicle-Mounted Work Platforms]
29 CFR §1910.68 – Manlifts [Powered Platforms, Manlifts, and Vehicle-Mounted Work Platforms]
For Amputations Information see this link: Amputations
And don’t expect any slack for paperwork omissions, like say, omitting a  directive control number or date on a record…

 

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And it looks really, really cool.

Chromium is added to steel to

  • Increase resistance to corrosion;
  • Increase resistance to oxidation;
  • Increase hardenability;
  • Improve high temperature strength;
  • Improve abrasion resistance in higher carbon grades.

Chromium forms complex chromium-iron carbides. These carbides go into solution into austenite very slowly, so assuring a long enough heating (soak) time before quenching is very important.
In stainless steels, ~18 % chromium is typical, (303, 304 austenitics), while analyses as low as ~12 % (403, 420), and as high as 26-28% grades are available.
In non-stainless steels, chromium is essentially a hardening element. It is often used in combination with nickel (a toughening element) to produce improved mechanical properties. In combination with molybdenum, chromium contributes to higher strength at elevated temperatures.
Chromium’s principal use is in stainless steels, where its resistance to oxidation provides the protection from oxidation and corrosion.
Chromium’s decorative properties made it a favorite among automotive and motorcycle enthusiasts. Its resistance to oxidation and staining and ability to take a high polish make it an easy choice for decorative yet functional parts. Chromium’s hardness and chemical resistance makes it ideal for protecting our tools.
Chromium has several oxidation states, Hexavalent chromium (CRVI) is of concern as an industrial environmental issue. Metallic chromium is not hexavalent, but flame cutting or welding of chromium materials may release haxavalent chromium. Chromic acid used for some chrome plating applications is hexavalent. Newer environmentally acceptable chromium finishes are trivalent. (CRIII) Link.
Chromium is named for the Greek word chroma, meaning color, as its salts are brightly colored. Chromium is a constituent of rubies, and is why ruby lasers give off their characteristic red light.
Final chromium fact: your body requires chromium. Chromium in your body  ranges from 6-100 ppb in blood, up to 800 ppb in various tissues. Depending on your mass, you might contain as much as 12 milligrams of chromium in your body.
Reference.
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This year I am going to celebrate Independence day as Interdependence Day. I am going to let my US side and my Canadian sides work together.  I invite you to join me, independently interdependent.  
I just love Independence Day and its northern cousin, Canada Day. Actually, I remember Canada Day as Dominion Day, but that just proves I’m an old fogie with Canadian roots.  

PMPA- North American means US and CANADA.

Independence Day is a US federal holiday commemorating our Declaration of Independence from the Kingdom of Great Britain in 1776. While most of us celebrate this holiday with patriotic displays, fireworks, cookouts, and much nationalistic fervor, I see this holiday as  celebrating the triumph and  coming of age of reason and representative government   vs.  the old  myth of divine right of kings and blind obedience. To me Independence Day is as much about the wisdom and intellectual achievement of our founding fathers as it is about nationalistic pride.  
My father would say “Son, you think too much.”  He would probably be right, but hey, he kept me well stocked in books and allowed me all the freedom to read that a kid could have.  
Thanks Dad.  
Unlike the US Independence Day holiday which recognizes separation, the Dominion Day Canada Day holiday recognizes the “uniting” of the 4  British North American colonies and the province of Canada  (which ended up split into two provinces, Ontario and Quebec) into a new  Kingdom- Canada, within the British Empire. This happened on July 1, 1867 according to the history books.  
I was never able to understand that particular arrangement, as the King of Canada would have been the King of England.  “How can the king of one country be the king of another country, and both be independent?” My  Canadian mother never got it through my thoroughly US cranium, though she tried. But then again, I was an intellectually unruly child…  
But the idea of the American side of my family celebrating independence and the Canadian side celebrating continued interdependence gives me the real subject for today’s blog:    
Interdependence day  
This year I am going to celebrate Independence Day as Interdependence Day. I am going to let my US side and my Canadian sides work together.  I invite you to join me, independently interdependent.  
Here are four hallmarks of our independent interdependence:  

  1. Citizenship
  2. Stewardship
  3. Diversity and Coexistence
  4. Sustainable Improvement

   Citizenship  
Citizenship to me is a code word for personal responsibility. To not do things against my own interest. Or against the interest of my “neighbors.”  As individuals first, but also collectively. Citizenship includes loyalty to the principles of our Constitution, and obedience to lawful authority;  But to me it is far more than that. Citizenship is a way of living in the world. Citizens are part of the solution process, not the problem.   

Citizenship problem.

  Under my definition, BP right now has a “Citizenship Problem.”  
Stewardship  
Part of that “Citizenship thing” is recognizing that our actions and decisions affect others,  and so we need to behave responsibly. Our shops use lean manufacturing processes to eliminate waste and so to not dissipate valuable resources that will be needed by others in the future.  Our shops are good stewards of the resources we have. While the press paints businessmen as stingy and greedy, the fact is that our drive to eliminate waste is to be good stewards of what we have, not just  to reduce costs. We have capital, employees, customers, and intellectual means of production that enable us, our families, our employees and their families, and our communities to  thrive. Recognizing this interdependence helps us realize that all of us can lead efforts for stewardship  for a better shop, home, community, state, province, country, and world.  
We’ll reserve comment on this aspect  regarding BP…  
Diversity and Coexistence  
My office is different than your office. Your house is different than mine. Your shop is different from hers. Her business model is different from his.  
PMPA’s North American Trade Association  model demonstrates how all of us, despite the fact that we compete, can also profit by sharing and approaching our markets and processes differently. By behaving as neighbors, professionals with a common mission, to make the parts that make today’s technologies serve all of us with improved safety, quality, convenience and quality of life.  
Viva la difference! It is not enough for us to tolerate differences, We need to embrace them. It is the richness of approaches that assures that all opportunities for profit (and service!) out of a given market or resource are achieved. ‘One size fits all’ never fits anybody real well.  
If you don’t like diversity, or differences, well, then have you considered  opening a shop in say, North Korea?  
Sustainable Improvement  
When I was growing up, the word “Progress” was as widely used as the word “Green” is today. I  like “Progress” better. Progress was generally used to mean growth. Improvement. Better. I am a big fan of continuous improvement. I have an internal principle that asks “is it better because of what I did?” I want my kids to do better than I did. I want this years’ business to be better than last years’.  
But what we didn’t ask back in the day when “Progress” was as worshipfully served as “Green” seems to be today was, “What is the cost?And how do we measure progress?”  
“Better for me,” at the cost of  “worse for you” is no bargain.  So I ask if the improvement is sustainable,  a genuine improvement? Or is it not sustainable? You know, like a Bernie Madoff Investment Fund Business Model?  
Sustainable improvement brings us back to Citizenship and Stewardship. Embracing Diversity- Coexistence helps us measure the impact of our improvements on all of us who might be impacted. Recognizing that we’re all impacted drives us to wanting to make improvements.  
Final thought  
Independence? Yes, I value that as giving me the agency to make the right decisions.  
Interdependence? Yes, for you and I, and approximately 6.7 billion other folks; 307 million of whom celebrate Independence Day, 33 million of whom celebrate Dominion Day Canada Day, we are also interdependent. That is why Citizenship/Stewardship (Quality, Professionalism, Fair Dealings, Service to others, and Mastery of our Craft) is so important.  
Happy Independence Day. Happy Interdependence Day. May your dedication remain focused on Citizenship, Stewardship,  Diversity and Coexistence, and Sustainable Improvement. No matter on which side of the border you live or make parts.  
Ultimately, we’re all customers. I’ll do my best. How about you?  
Happy Interdependence / Independence Day!

Photo credit  
Cute Flag Wavers
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Cutting fluids contribute 3 ways to our machining processes.

Critical to our shops for three reasons.

1) They provide lubrication. Lubrication reduces friction. Reduced friction means less heat. Less heat means better dimensional capability and faster cycle times are possible.
2) They help remove heat. Even though they provide lubrication, some frictional heat is produced. So the ability to capture, and remove heat is an important property of metalworking fluids.
3) They prevent the welding of workpiece material onto the tool.Pressure of the workpiece against the tool and the heat and temperatures involved contribute to the buildup of workpiece material on the tool. Cutting fluids provide an antiweld film to discourage this.
For a thorough tutorial on the subject of cutting fluids, check out Barbara Donohue’s article  on this subject in Today’s Machining World click this link.
Photo credit.