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Corrective Actions help Incident Investigations become PROACTIVE

Our investigation process is purely reactive to undesired consequences, but our corrective action(s) process can turn it into a PROACTIVE activity.  It takes a level of safety maturity to move in this direction. It will come naturally once that maturity level is reached and the workplace strongly desires (and respects) to be a LEARNING culture. …...

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Safety Thought of the Week… Safety is not the absence of Accidents

Safety is not the absence of Accidents. Safety is the presence of Defenses and Capacity.   Dr. Todd Conklin… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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NFPA 704 – size matters!

SAFTENG audits are known to be “detailed” (the nice way to say it).  We believe that when we are working with MINIMUM PERFORMANCE STANDARDS such as OSHA standards and those standards adopted by a facility to support compliance with these minimum standards, all the details matter.  One of the most deficiencies we come across involves…...

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The real, and CRITICAL, date of your PSM/RMP Audit(s)

I get about a dozen calls a year from folks asking me about their PSM/RMP due dates.  I try to explain that of course OSHA or EPA can cite the facility if the audit is past due.  For example, the last audit was done the 2nd week of February 2020, it is expected that the…...

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EPA RMP Citations @ crude fractionation process (Flammable Gases & $85K)

Respondent has a crude fractionation process at the Facility. EPA inspected the Facility on February 14 – 17, 2022, to determine the Respondent’s compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68. Butane, isopentane, ethane, propane, and pentane are “regulated substances” pursuant to 40 C.F.R. § 68.3. The threshold quantity for butane,…...

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EPA RMP Citations @ manufacturing facility (Flammable Gases & $233K)

Respondent manufactures a range of specialty surfactants for use predominantly in the oil and gas industry. The process of ethoxylation involves reacting ethylene oxide with various common chemicals, such as fatty alcohols and phenols, to produce a variety of products. The plant can also use propylene oxide instead of (or as well as) ethylene oxide…...

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Materials of Construction and Compatibility MATTER

This is from an EPA Multimedia inspection that looked at a chemical process that was below the TQ, so they used the RMP GDC to inspect.  What they found in the flammable process was that… … several of the facility’s components were made of aluminum. One condenser was installed with malleable iron tubes instead of…...

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Understanding the electrical classification model

Three (3) fundamentals are behind the “electrical classification” model for hazardous locations.  These three fundamentals mirror our approach to other workplace hazards, and understanding these three fundamentals will help make a lot of sense out of NFPA 497/499 and 1910.307…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member?...

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Comparing Classes/Divisions with Zones

The US still uses the Class and Division system to classify electrical systems in hazardous locations.  However, outside the US, the Zone system is more widely used.  Manufacturers are beginning to list their equipment based on the Zone(s) it is rated for, which can cause translation confusion.  The table below may be of help…. Membership...

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CONSISTENCY matters in HFE (Colors)

I have mentioned this fundamental HF design need in several of my postings.  CONSISTENCY is key in helping reduce human error.  I like to use STOP signs as my example.  But here are some fundamental principles when analyzing computer screens, workplace signs, etc., when it comes to COLORS…… Membership Required You must be a member...

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Runway Safety Trends and Runway Incursion Analysis

We can learn a lot from Aviation Safety!  I came across this 2017 presentation on Runway Safety Trends and Runway Incursion Analysis and just loved how they analyzed their data to identify the trends, causes, and contributing factors.  Some of the data may be alarming, but that is not my intent.  This is how we…...

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