“Despite efforts to improve safety, several hundred accidents happen every year, and most such crashes are blamed on human error or outdated signaling equipment.” Active Failures vs. Latent Organizational Failures These conflicts are always in the spotlight after tragedies. It took me many years working for some great leaders who always challenged me to look […]
The establishment of a positive culture of safety within an organization is dependent on the following:
I came across these nine bullets from an SMS for a UK government agency. It may be the best-summarized listing of the behaviors and language we should see from the top executives within our organizations. I realize that one of the references talks about “prioritizing safety”; and although I am not a fan of that
They are NOT there to perform a causal analysis. They are there simply to determine if one or more of its standards were violated. And in some cases, they may even issue citations that had zero to do with the event that brought them on-site. So addressing OSHA’s citations is NOT the sole path forward
We hear a lot about our biases showing up in many SMS elements and how these biases hamper the SMS and mislead us. But not all biases can be a bad thing. One element where our biases shine brightly is in the Causal Analysis of accidents. For decades now, we have been told over and
A process covered under 40 CFR Part 68 is eligible for Program 1 requirements if it meets all of the criteria listed at 40 CFR §68.10(b). One of those criteria is that the distance to a toxic or flammable endpoint for a worst-case release assessment is less than the distance to any public receptor. Are
Performance of the hazard assessment required under 40 CFR Part 68, Subpart B, includes analysis of both worst-case release scenarios (40 CFR §68.25) and alternative release scenarios (40 CFR §68.28). In each of these analyses, passive mitigation systems may be taken into consideration. If a tank has a “double wall,” does that qualify as “passive
I use propane as a raw material in my manufacturing process. I lease the tank from the propane supplier. The supplier does all the maintenance. My staff never work on the equipment. What should I do?
Which states have been granted a delegation of EPA’s authority to implement and enforce the risk management program rule?
Certain exemptions may apply to determine whether more than a threshold amount of a regulated substance is present at a stationary source under 40 CFR Part 68. One exemption is for regulated substances that are “manufactured, processed, or used in a laboratory at a stationary source under the supervision of a technically qualified individual as
I recently submitted my five-year RMP update required by section 68.190 (b)(1) and included my accident history for the previous five years. Two months later, we had another reportable accident. Do I have to do anything to revise my RMP?
If an owner of a stationary source leases propane tanks from a gas supplier, who is responsible for preparing and submitting the risk management plan (RMP) addressing the propane tanks?
