When Can a Company Be OSHA 1910.106 Compliant but Still Experience Injuries in Water Treatment Facilities?
Compliance with OSHA's 1910.106 standard for flammable liquids is crucial, but it's not a silver bullet for safety in water treatment facilities. Even with strict adherence, hazards can still lead to injuries. Let's dive into why this happens and how to address these gaps.
Understanding OSHA 1910.106 Compliance
OSHA 1910.106 sets forth requirements for the safe handling, storage, and use of flammable liquids. This includes everything from the design of storage cabinets to the training of employees on handling these substances. Compliance with this standard is non-negotiable for any facility dealing with flammable materials.
Why Injuries Still Occur
Despite being compliant, accidents can still happen due to several factors. Here are some common reasons:
- Human Error: Even with the best training, mistakes can occur. An employee might forget to follow a procedure or misjudge a situation.
- Equipment Failure: Machinery and safety devices can fail unexpectedly, leading to hazardous situations.
- Environmental Factors: Unforeseen conditions like extreme weather or natural disasters can compromise safety measures.
- Insufficient Training: While compliant, the training might not be thorough enough to cover all potential scenarios.
Case Study: A Real-World Example
I once worked with a water treatment facility in Southern California that was fully compliant with OSHA 1910.106. Yet, they experienced a near-miss incident when a valve failed during a routine maintenance operation. The root cause? A combination of human error and equipment failure. This incident highlighted the need for ongoing safety assessments and not just reliance on compliance alone.
Strategies to Enhance Safety Beyond Compliance
To reduce the risk of injuries, consider these strategies:
- Regular Safety Audits: Conduct frequent audits to identify and mitigate risks beyond the scope of OSHA 1910.106.
- Advanced Training Programs: Implement training that goes beyond the basics, including scenario-based learning and regular refresher courses.
- Maintenance and Inspection: Ensure all equipment is regularly maintained and inspected to prevent failures.
- Incident Analysis: Use incident reports to learn from near-misses and accidents, adjusting safety protocols accordingly.
By integrating these strategies, facilities can create a more robust safety culture that goes beyond mere compliance.
Resources for Further Learning
For those looking to deepen their understanding of safety in water treatment facilities, consider the following resources:
- The OSHA website provides detailed information on 1910.106 and other relevant standards.
- The American Water Works Association (AWWA) offers resources and training specifically tailored to water treatment safety.
- NIOSH publishes research and guidelines on occupational safety and health, including in water treatment facilities.
Remember, compliance is the starting point, not the finish line. By continuously improving safety measures and learning from industry resources, water treatment facilities can significantly reduce the risk of injuries.


