Safety Info Posts

Selling safety is much like selling quality (video)

Much can be said about the safety movement mimicking the 1990s Quality Movement in the US automobile industry. Does anyone remember Ford’s “Quality is Job 1” ads? It was a huge branding image effort to compete with Toyota and Honda, who were stealing market share based on the QUALITY of their vehicles. Even today, Toyota…...

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Two (2) NH3 nurse tanks catastrophically fail in 3 months

This past week, we saw the 2nd catastrophic failure of an NH3 nurse tank in three months.  This is indeed a rare occurrence.  Both incidents appear (from news accounts and photos) to be circumferential weld failures on these vessels.  Both vessels failed while they contained NH3 (levels unknown), but neither was actively being filled at…...

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Does it bother anyone when we see “Hearing Protection Required” sign?

Does it bother anyone when we see this sign? I am not telling you anything you don’t already know… Hearing Protection is very much like Respiratory Protection – it comes with some serious limitations and is based on the worker’s EXPOSURE. However, as a consultant working in plants, I am always told in my contractor…...

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Federal Motor Carrier Safety Administration (FMCSA) audit pays off

I am not a big fan of government intervention, but in the safety envelope, they play a role in validating that minimum standards are being met.  The Federal Motor Carrier Safety Administration (FMCSA) audits service providers who inspect HAZMAT transportation containers.  Beginning in June 2023, during an investigation at a manufacturer in Fresno, California, FMCSA…...

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Federal Motor Carrier Safety Administration (FMCSA) audit pays off Read More »

PHMSA Notice of Proposed Rulemaking: Safety of Gas Distribution Pipelines and Other Pipeline Safety Initiatives

PHMSA proposes revisions to the pipeline safety regulations to require operators of gas distribution pipelines to update their distribution integrity management programs (DIMP), emergency response plans, operations and maintenance manuals, and other safety practices These proposals implement provisions of the Leonel Rondon Pipeline Safety Act—part of the Protecting our Infrastructure of Pipelines and Enhancing Safety…...

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Before we can achieve a ZES, we must first define and quantify what precisely a form of “hazardous energy” is

I don’t think many safety pros would argue with this statement:  LOTO requires that all forms of hazardous energy be taken to a ZES before servicing and maintenance begin. But I have had many discussions about DEFINING and QUANTIFYING what a “hazardous form of energy” is.  Since OSHA has not quantified the term “hazardous energy”,…...

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Before we can achieve a ZES, we must first define and quantify what precisely a form of “hazardous energy” is Read More »

Does OSHA have the authority to set “reasonably necessary or appropriate” workplace-safety standards?

The United States Court of Appeals for The Sixth Circuit says it does.  More than fifty years ago, Congress passed, and President Nixon signed into law, the Occupational Safety and Health (OSH) Act, 29 U.S.C. § 651 et seq. Throughout the next half century, challenges to the constitutionality of the Act have been uniformly rejected…....

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Does OSHA have the authority to set “reasonably necessary or appropriate” workplace-safety standards? Read More »

Cuts so deep that supervisors can’t supervise (Part II)

Earlier this month, I wrote Cuts so deep that workers can’t participate in their safety process concerning how reorganizational changes can lead to a lean workforce that the workers who need to participate in their safety process do not have the time to.   Now, let’s take a look at what happens when the layer of…...

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Professor James Reason had a similar image to today’s “Work as imagined vs. Work as done” model

Professor James Reason had a similar image to today’s “Work as imagined vs. Work as done” model. This image is from his 1997 book titled “Managing the Risks of Organizational Accidents“ It shows the “ideal” layers of protection model (i.e., the pieces of cheese with no holes) vs. the “reality” (i.e., the pieces of cheese…...

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Professor James Reason had a similar image to today’s “Work as imagined vs. Work as done” model Read More »

The results are in… 1/4 turn valves need that little sliding lockout tab

One of the most common valves used in industrial settings is the 1/4-turn ball valve.  From 1/4″ up to 6″, these valves are everywhere, regardless of the risks they may pose.  Recently a client and I discussed these valves and their risk in highly hazardous chemical processing.  I have had several incidents over my career…...

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The results are in… 1/4 turn valves need that little sliding lockout tab Read More »

Safety and the 100-hour rule theory

The 100-Hour Rule is the theory that to master a topic and get the benefits of greatness doesn’t need to take 10,000 hours. Rather, it can often take approximately 100 hours if you break down skills into rare and valuable micro-skills. It is an exciting study that seems to have some validity to it.  Basically,…...

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