Bryan

What is an “industry standard”?

If I had a nickel for every time I have heard this phrase over the past 20 years of consulting… “industry standard,” I would have retired after 5 years. What is an “industry standard”? It is far from being a Recognized and Generally Accepted Good Engineering Practice (RAGAGEP), that’s for sure. However, companies with an…...

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PRCS FATALITY – RAILCAR; O2 Deficiency

The contractor, 35, entered the railcar to conduct an air quality test while two other men waited outside. The two men noticed he was unresponsive and began to assist him. Firefighters determined the person in question was lying unresponsive inside the railroad tanker car, according to the department. Authorities said the man was a contractor…...

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Management Oversight and Risk Tree (MORT)

MORT was first developed in the USA to analyze the root causes and causal factors for incidents in the nuclear power and aviation industries, but it has now been applied in many industries. However, it seems to be a “lost art” these days! MORT is a pre-populated tree based on a model of an organization’s…...

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FRA’s position on injury incentive programs mirrors OSHA’s

Title 49 Code of Federal Regulations (CFR) Part 225 requires railroad carriers to report all employee injuries that fall under the regulations to ensure FRA is provided with accurate information concerning the hazards and risks that exist on the Nation’s railroads. Part 225 also requires all railroads to abide by their Internal Control Plans, including…...

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Safety Thought of the Week… Wind Chill

Since we are in a snow apocalypse here in the Midwest, I thought I would lose my mind hearing all the “weather professionals” declaring that with wind chills below zero, the roads will freeze as the salt won’t work below 15F. And I thought these were “science-based” professionals. TIP: Wind chill is how the temperature…...

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Not the PR you want

This was the headline in our local news after a chemical company failed to participate in a community meeting after their product leaked from a railcar sitting in a railyard about 4 miles from the plant. It took several days to get folks back into their homes; as you can imagine, they were unhappy. However,…...

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OSHA may allow it, but NFPA and IFC allow it ONLY under “special purposes”

I have spent my career working with flammable liquids, and those who have followed my writings on the topic understand why I have stopped using 1910.106 as my baseline flammable liquid safety standard and instead began using either the IFC or NFPA 30. I have been involved in several serious events where atmospheric storage tanks…...

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Risk Assessment Fundamentals (UK’s HSE)

The risk assessment process must identify what could cause harm in the workplace, who and how it could harm, and consider what control measures are required to reduce the risk to As Low As Reasonably Practicable (ALARP)and tolerable. Control measures that have been identified must be implemented, clearly communicated to personnel, maintained, and used properly…....

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Safety Thought of the Week – Systems exist in a changing world

The environment, organization, economics, capabilities, technology, and regulatory context all change over time. This backdrop of continuous systemic change ensures that hazards and how they are managed are constantly changing. Progress on safety concerns anticipating how these kinds of changes will create new vulnerabilities and paths to failure even as they provide benefits on other…...

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Safety Thought of the Week… from Vincent van Gogh

Now, I’m 100% certain that Mr. Gogh did not have the safety profession in mind when he said the following, but it could not be more true in the context of our profession. Few professions need passion like that of the safety profession. Find me a world-class safety pro, and we will have one who…...

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LINE BREAK GONE BAD (R-22 & Compressor Oil Flash Fire)

At 11:00 a.m. on April 10, 2023, Employee #1, 55, was performing maintenance on the refrigerant lines of a Liquid Chiller used for air conditioning at an airport terminal. Employee #1 was removing the Electronic Expansion Valve (EEV) from the hot gas bypass line. The line contained R-22 refrigerant and compressor lubricating oil at a…...

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Flammable Liquid Containers and Size

29 CFR 1910.106(d)(2)(iii) specifies the maximum container size depending upon the category of flammable liquid and the type of material from which the container is made. However, it is not uncommon to see flammable liquids in plastic and glass containers that are larger than allowed by the standard. In many cases the chemical is in…...

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