I know this can be a sensitive topic, even though I am not a fan of the “Zero Harm” approach, but when it was presented like this, I have to say I support all seven (7) of these functions within a Safety Management System (SMS). VISION ZERO – 7 Golden Rules – for zero accidents…...
VISION ZERO may not be all that bad when it takes this approach Read More »
R 408.17313 Proper use, handling, storage, and containment of firefighting foam concentrate. Rule 7313…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
On or about January 31, 2023, representatives of the EPA inspected Respondent’s Facility to determine compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68. Information gathered during the EPA inspection revealed that Respondent had over 10,000 pounds of anhydrous ammonia in a process at its facility. Information gathered during the EPA inspection…...
EPA issues RMP Program 2 citations @ fertilizer business (NH3 & $82K) Read More »
The criteria for determining when to retire or repair FR clothing/garments/accessories MUST provide measurable or easily identifiable damage. The following are some means to DEFINE and QUANTIFY these deficiencies:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
When does FRC fail it’s user inspection? Read More »
“People are actually very reliable, but there are many opportunities for error in the course of a day’s work, and when handling hazardous materials, we can tolerate only very low error rates (and equipment failure rates), lower than it may be possible to achieve. We may be able to keep up a tip-top performance for…...
Weekly Safety Thought… Human Performance Read More »
“People are actually very reliable, but there are many opportunities for error in the course of a day’s work, and when handling hazardous materials, we can tolerate only very low error rates (and equipment failure rates), lower than it may be possible to achieve…. Membership Required You must be a member to access this content.View...
Safety Thought of the Week – People are actually very reliable Read More »
In 2023, I began taking issue with the condition of Flame Retardant Clothing (FRC) being used in REQUIRED areas and tasks. We see garments that in no way would pass a “routine inspection” per NFPA limitations. My go to RAGAGEP for this is NFPA 2113, Standard on Selection, Care, Use, and Maintenance of Flame-Resistant Garments…...
A Health and Safety Executive (HSE) investigation into a gasoline overfill of a carbon adsorption vapor recovery unit (VRU) revealed concerns with the design of the VRU. The overfill prevention system was NOT independent of the basic process control system (BPCS). When the BPCS failed the overfill prevention system also failed. This resulted in loss…...
OSHA’s PSM standard is over 30 years old, and EPA’s RMP standards/rule is approaching its 30th birthday fast. They are so 20th century (LOL)! This article is about how some of my clients are approaching their 3-year audits required by both standards. This approach embraces the “audit element” of the process safety management system as…...
PSM/RMP Auditing in the 21st Century Read More »
If management believes safety is all about workers behaving as they have been trained, then we should be able to save thousands of dollars by ordering keyboards with no “delete” button. After all, if we expect workers to make no errors, mistakes, or violations in executing their jobs, we should have the exact expectations within…...
Here is something to ponder in 2024… (Errors, Mistakes, and Violations) Read More »
The value of a Root Cause Analysis and Corrective Action Plan process to a business If the critique process is effective and an organization successfully determines why the event occurred, the appropriate corrective action can be achieved. The avoided cost associated with recurrence and improvement in performance is the organization’s dividend…. Membership Required You must...
[Last] Safety Thought of the Week 2023 Read More »
Respondent owns and operates a chemical warehouse and repackaging facility. From November 2 through November 5, 2021, EPA performed an inspection of the Facility to evaluate compliance with Section 103 of the Comprehensive Environmental Response, Compensation and Liability Act (“CERCLA”), EPCRA Sections 304-312, and CAA Section 112(r). Based upon the information gathered during the Inspection…...
EPA issues RMP & EPCRA citations @ facility (NH3, SO2, Cl2 & $69K w/ $109K SEP) Read More »
