This article discusses how a facility would need to get one of its coded pressure vessels repaired, altered, or re-rated. The article will cover pertinent code and jurisdiction requirements and the differences among the American Society of Mechanical Engineers (ASME) Code, the National Board Inspection Code (NBC), and American Petroleum Institute (API) requirements, as well…...
National Board Inspection Code vs. API 510 Read More »
A Process Hazard(s) Analysis is a thorough, orderly, and systematic approach for identifying, evaluating, and controlling the hazards of processes involving highly hazardous chemicals. The facility shall perform a process hazard analysis on all processes covered by EPA’s RMP rule and/or OSHA’s PSM standard. The process hazard analysis methodology selected must be appropriate to the…...
Process Hazards Analysis Techniques (Methodolgies, Resources, and Time) Read More »
HAZWOPER EMERGENCY RESPONSE PLAN DEVELOPMENT GUIDELINES(Elements of an Emergency Response Plan)1910.120(q)(2) (i) Pre-emergency Planning and Coordination with outside parties Facilities are required in the Superfund Amendments and Reauthorization Act (SARA) title III to coordinate their activities with outside response organizations and emergency response organizations. The emergency response plan (ERP) MUST address coordination with outside emergency…...
Breaking down 1910.120(q)(2) Written ERP requirements Read More »
Are there any recordkeeping requirements specified in the risk management program (RMP) regulations in 40 CFR Part 68? The owner or operator of a stationary source that is subject to the RMP regulations must maintain records supporting the implementation of Part 68 for five years (§68.200)…. Membership Required You must be a member to access...
Are there any RMP recordkeeping requirements? Read More »
Error Management (EM) has two (2) components: error reduction and error containment Error reduction comprises measures designed to limit the occurrence of errors. Since this will never be wholly successful, we also need error containment measures designed to limit the adverse consequences of those errors that still occur. At this general level, EM is indistinguishable…...
What is Error Management? (Reason, 1997) Read More »
Fostering the principles for a strong safety culture is one of the most challenging tasks facing a management team. Successful leadership achieving a strong safety culture will most likely move an organization to the next level of human performance. A leader is any individual who takes personal responsibility for his or her performance as well…...
I have used this tool, with some modern-day modifications, for years. When I was a safety manager of a facility I would constantly be looking for these indicators as a means to validate what I was “feeling”. As safety pros, we have a sixth sense of how things are going, but there are so many…...
Where is your safety culture? Read More »
“Name, blame, shame, retrain” is an often-used phrase for older ineffective paradigms of safety management and accident analysis. Dr. Rosabeth Moss Kanter of Harvard Business School phased the situation this way: “Accountability is a favorite word to invoke when the lack of it has become so apparent.” Kanter, 2009 The concepts of accountability, culpability and…...
Accountability, Culpability and a “Just Culture” (Dr. James Reason) Read More »
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To vent or Not to vent? Read More »
Earlier, I outlined the six (6) stages of a Behavior Modification Intervention. Now, I want to discuss how the same six-step process used to change the behaviors of hourly workers can be used to promote critical health and safety behaviors amongst management personnel. Management behavior will heavily influence the success or failure of a Behavior-Based…...
Using Behavior-Based Observation Process to promote MANAGEMENT BEHAVIORS Read More »
Several studies have evaluated the effectiveness of behavioral modification programs in improving workplace safety. These studies have focused on establishing the following: their ability to decrease accidents/injuries, their ability to increase safe behavior and which components in a behavioral observation safety processes are most important in changing unsafe behavior and reducing accidents and injuries… Membership...
Do Behavioral Observation Safety Processes Change Behaviors? Read More »
In many processes, the use of a rupture disc (RD) between the vessel being protected and the Relief Valve (RV) is a fairly common practice. This is ALWAYS done for design necessities and not just “because”. Some processes could be corrosive to the RV internals, at least this is the most common reason for this…...
Rupture Disc between Pressure Vessel and Relief Valve (and after the RV) Read More »
