Bryan

Human Factors Engineering – Center High-Mounted Lamps

One of my favorite examples of Human Factors Engineering is the Center High-Mounted stop Lamps.  We have all seen them on every personal vehicle manufactured today.  They are now a safety requirement.  But it was not always that way.  So, what is a CHMSL?  CHMSL are red stop lamps mounted on the center line of…...

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How does OSHA and EPA define “retail establishment” in regards to their “exemptions” from PSM/RMP

Retail facilities are exempted from PSM requirements.  At first glance, it appears this is a pretty broad exemption, as the standard just states. This section does not apply to:1910.119(a)(2)(i) Retail facilities; But as I wrote about last month, not all retail facilities selling a PSM Highly Hazardous Chemical (HHC) in the USA are exempt. In…...

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EPA’s RMP and Program 3 NAICS #’s

As we have discussed before, the EPA broke down its RMP rule into three (3) programs, and each program has criteria that will place the process in one of the three. However, the one criterion that confuses some businesses is how EPA used the North American Industry Classification System (NAICS) to qualify a process for…...

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Testing and Inspection of Bonding/Grounding Systems

The proper installation of bonding and grounding systems is important in the protection of personnel and property. At the time of installation, a resistance test is needed to confirm electrical continuity to ground. Evaluating the maintenance requirements, the bonding and grounding system can be divided into three categories:… Membership Required You must be a member...

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Catastrophic Failure during pneumatic pressure test

Jan 26, 2006  – An accident occurred in a factory in Brazil during pneumatic pressure testing with air from pipework around a tank.  There were no blind flanges placed to isolate the pipework to the tank; only the valves were closed. Probably one or more valves failed or were not closed as the tank underwent…...

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Am I required to have an Emergency Action Plan?

In the world of process safety, this is a no-brainer; but in normal manufacturing facilities, the answer can be quite confusing.  Bottom line… if your facility has a PSM-covered process (even an RMP Program 2 or 3 process) we are REQUIRED to have an EAP that complies with 1910.38.  But when we are not a…...

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UPDATE – Calling the National Response Center

Who at your place of business calls the National Response Center after your business has experienced a chemical incident.  Not many people have ever had to call this center (luckily!) but if your business ever does have a “reportable release”  a call just like this one MUST BE MADE within 30 minutes after you have…...

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Nuclear industry’s take on HOP’s Five Principles

Human Performance Improvement (HPI) is the systematic process of determining desired performance, continually monitoring performance, discovering and analyzing performance gaps, designing and developing effective interventions, implementing these interventions, and continually evaluating the results of improvement interventions within performance monitoring to ensure that the improvement process takes place.  The goal of excellence in human performance is…...

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Deep dive into HFE with the NRC’s Human Factors Information System (HFIS)

Humans are integral to the safe operation of a nuclear power plant. In the late 1970s, NRC began to focus on protecting and ensuring adequate training of plant staff to perform their assigned tasks. The NRC studied factors affecting performance, such as the effects of shift work on health and whether control room simulators would…...

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Entry into PRCS’s protected by a fixed fire protection system

I could have sworn I had already written about this hazard, but I’m guessing it was inside one of my social media groups.  So BUCKLE UP, Butter Cup, as this is going to make a lot of folks unhappy.  Question:  Do I have to isolate my fixed fire suppression system protecting my PRCS?… Membership Required...

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