There is NO exception in either 1910.146 or 1926.1201-.1213 for NOT having a rescue plan for “permitted entries” into a PRCS. There is an exception for the “Non-Entry rescue method,” BUT there is NOT one for having a rescue service readily available when the space being entered is a PRCS and the entry method is…...
On October 9, 2023, at about 11:30 a.m., three (3) technicians tasked with performing maintenance work in an underground fuel reservoir died after they entered the underground tank. All three died from suffocation. This tragic incident is like the many before! A single entrant entered the space and became incapacitated, leading his/her co-workers to go…...
I had the pleasure of teaching another Advanced Course on Process Safety (40-hr). When discussing Relief Systems, their design, and their RAGAGEP(s), the UPWARDS and UNOBSTRUCTED piece got many questions. ALL RAGAGEPs regarding PRDs will state “UPWARDS and UNOBSTRUCTED” or similar language. Even the older OSHA standards uses the phrase “Upward and Unobstructed” in the…...
Once we get to the place where we can agree that fluids and gases are “stored energy” and that those “stored energies” have to be bled/drained to achieve a Zero Energy State (ZES), we can then discuss the potential hazards these necessary actions can create. I have written a lot about using 1/4 turn ball…...
A few weeks ago, I shared my thoughts on whether a business was ready for a Behavior-based Safety process (BBSP). Since then, I have been asked what some “indicators” could be that a business is “culturally ready” for a BBSP. And for me, it can all hinge on how management EMBRACES NEAR-MISS gifts. Yes, near-misses…...
At 10:00 p.m. on March 26, 2023, an employee was working as a machine operator for a corrugated box manufacturer. The employee was possibly adjusting or cleaning the electric photo eyes on a bundle breaker machine. The machine was energized, in run mode, and not locked out. The employee broke the light beam, and the…...
I am seeing a lot of disinformation regarding Behavior Based Safety, and of course, those dis’ing BBS have the latest and greatest approach to fix all your safety problems. But don’t be fooled. BBS is a tool in our safety toolbox and like any tool in the hands of UNTRAINED personnel, it can be misused…...
A Process Safety Management System (PSMS) is built off the SIF approach many companies are dipping their toes into today. If you are a PSM/RMP-covered facility, you already have an SMS; it’s just called a PSMS, and it is a 14-element SMS that is ALL about the SIF approach. YOU ARE CLOSER TO SIF then…...
Too often, management will view the decline in recordable injuries as a positive trend without understanding the driving force(s) behind this trend. It is common to find a decrease in reportable injuries in line with a decrease in total reported incidents. We call this “Low Confidence”. We can have a higher level of confidence when…...
I am updating my SMS/HF course for a course in October. This may be helpful to some. This is the James Reason HF model. I have shared other graphics of his model over the years, but this one and the one from our friend at the UK’s HSE are my favorites. I hope that some…...
Someone pinch me! It is 2023, and I’m still teaching HAZMAT, Hot Work, and PRCS courses, where most students use direct-reading instruments daily. And yet, none of them have ever been trained on the LIMITATIONS of the brand/model of direct-reading instruments they use. There are dozens of reasons why this is what it is, but…...
One of the biggest mistakes we see in BBS processes is the fundamental misunderstanding of a BBS process’s role in an SMS. Each observation is NOT about looking for unsafe behaviors; rather, it should be more about reinforcing the SAFE behaviors. Suppose an organization has a high rate of observed deviant behaviors from prescribed Safe…...
