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Work-as-Done vs Work-as-Imagined

Many safety management systems are initially developed in a theoretical environment or for ideal situations with implicit and explicit assumptions about the system’s optimal performance, equipment, and human activities. This is often called WORK-AS-IMAGINED and is formally documented in training, procedures, and equipment operating manuals. Differences between the designed performance or WORK-AS-IMAGINED and the realities […]

Knowing the limitation of your respiratory protection can mean the difference between life and death

Once again, a DOT container cleaning company had another fatal PRCS incident (2020) where we have an entrant and a would-be rescuer dying in a hazardous atmosphere – oxygen deficient.  In this incident, the would-be rescuer donned a full-face Air Purifying Respirator before he attempted his rescue effort but was overcome by the atmosphere and

Did you know… red hydrants are the worst

Recently I was at an HOA meeting for my neighborhood because of some concerns some homeowners had after a home fire.  Like most folks, everyone can recognize the object to the left – quite possibly one of the most recognized safety objects of all time.  And the color of the hydrant is red, but what

EPA issues RMP citations @ food plant (NH3 & $84K)

Respondent operates a “stationary source” and has registered an RMPlan with the EPA for its Facility and has developed an RMProgram accidental release prevention program for the stationary source.  Respondent operates an ammonia refrigeration process that has on-site storage of 15,416 pounds of anhydrous ammonia.  On December 11, 2018, the EPA conducted an on-site inspection

Technical Safety BC issues two (2) Ammonia Refrigeration Safety Orders

Technical Safety BC (British Columbia) has issued two new safety orders regarding ammonia in refrigeration plants.  Failure to comply with the requirements of these safety orders may result in enforcement action under the Safety Standards Act and associated regulations. These two (2) safety orders are: Safety Order SO-BP-2021-01: Secondary Coolant Safety Order SO-BP-2021-02: Emergency Discharge

FAILURES of true “facility siting” – our “zoning” process is broken and dangerous! (Part II)

Back in February of this year, I posted an article on how badly broken our “Industrial Zoning” process is broken in the USA.  The article was titled: “FAILURES of true “facility siting” – our “zoning” process is broken and dangerous!” and it was about a chemical plant’s pleas to the city council to not rezone

Spring is here and ammonia transfers are at their peak for spring application

The number 1 failure that causes releases of anhydrous ammonia in agricultural and bulk transports is hose failures!  Without a doubt, at a fertilizer distribution center, loading and unloading DOT containers via transfer hoses pose the greatest risk for a catastrophic event.  So special attention is deserving when it comes to the hose(s) we will

My first exposure to Safe Work Permits was because of OSHA’s HAZ COMM standard – not PSM

Most safety professionals attribute “safe work permitting” to process safety, Line Breaks/Process Openings, LOTO, Hotwork, and PRCS.  But my first exposure to work permits was because of OSHA’s Hazardous Communications standard… 1910.1200(e)(1)(ii) The methods the employer will use to inform employees of the hazards of non-routine tasks (for example, the cleaning of reactor vessels), and

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