The RMP Amendments, finalized on January 13, 2017, included a requirement for owners or operators of a stationary source to engage in emergency response coordination activities (40 CFR §68.93). The regulatory text in 40 CFR §68.10(b) states that compliance with these activities must be completed by March 14, 2018. Because the RMP Amendments were not…...
I want to share a perfect failure scenario that happened to me and has been happening to me since April 2021. And yes, I see the world through the lens of a safety engineer – hate me for it if you must. The failure is 99% my fault for trusting a simple financial tool via…...
Most formally educated or well-trained safety professionals are familiar with the Hierarchy of Controls. We use this approach daily in our work to reduce the likelihood of an event and/or the event’s severity. Mr. Kletz always had a different take on using this philosophy in process safety and as always – he nailed it!… Membership...
Respondent has an Ethanolamines unit used for chemical manufacturing purposes at the Facility that has greater than a threshold quantity of anhydrous ammonia. EPA Findings of Violation Count 1 – Quality Assurance… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
At 9:00 a.m. on January 31, 2022, an employee who worked as a General Laborer fo r an Industrial Nursery was filling propane cylinders from a bulk propane tank. As the employee was finishing filling a cylinder, he began to remove the filling hose before shutting off the propane. As a result, the gas escaped…...
Investigations of accidents in a number of hazardous domains suggest that a cluster of organizational pathologies—the “vulnerable system syndrome” (VSS)—render some systems more liable to adverse events. This syndrome has three (3) interacting and self-perpetuating elements: Blaming front-line individuals, Denying the existence of systemic error provoking weaknesses and Blinkered pursuit of productive and financial indicators…...
productThis week I have been helping a client/friend understand what a true non-entry rescue system looks like and how it functions. Back in July 2011, I wrote an article titled “CS Rescue… Tripods and Winches and a false sense of security” to help facilities understand the vast limitations of the traditional tripod and winch setup. …...
The respondent operates a water chlorination process. On July 27, 2021, EPA conducted an announced inspection of the Facility. The Facility maintains a maximum inventory of 14,000 pounds of chlorine, a regulated substance, as a liquified compressed gas in 1-ton cylinders. Here are the findings from the inspection:… Membership Required You must be a member...
I found another ppt from years ago, dusted it off, and updated it for a client. This is based on many of the HOP/HPI/Resiliency talks we hear these days. But know this, without trust, NOTHING will work in our effort to improve the worker’s safety. My favorite saying on trust is from Dr. Clive Lloyd:…...
After the month I have witnessed, this image came to me this weekend as I reflected on the state of safety in the USA. I have mentioned before, has the compliance model done more harm than good? I mean, OSHA has made a huge impact on workplace safety. Still, once a business achieves “compliance” (and…...
Light hydrocarbon was released through a pinhole breach of an insulated process pipe. A plant operator detected an abnormal hydrocarbon odor and immediately responded as per site emergency protocol. A localized possible breach was identified, and the processing unit was safely shut down for further investigation. A 3-inch insulated pipe connecting process piping to…...
If you have not yet read Clive Lloyd’s “Compliance to Care”, it is a must-read. Here are my five (5) favorite points he makes:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
