Safety Info Posts

Using Behavior-Based Observation Process to promote MANAGEMENT BEHAVIORS

Earlier, I outlined the six (6) stages of a Behavior Modification Intervention. Now, I want to discuss how the same six-step process used to change the behaviors of hourly workers can be used to promote critical health and safety behaviors amongst management personnel.  Management behavior will heavily influence the success or failure of a Behavior-Based…...

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Rupture Disc between Pressure Vessel and Relief Valve (and after the RV)

In many processes, the use of a rupture disc (RD) between the vessel being protected and the Relief Valve (RV) is a fairly common practice.  This is ALWAYS done for design necessities and not just “because”.  Some processes could be corrosive to the RV internals, at least this is the most common reason for this…...

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OSHA PSM Citations @ food plant (Fatality, NH3 & $1.1M)

Citation 1 Item 1 Type of Violation: Serious; $4,500 Section 88.4 – Code of Iowa (2007) 88.4: The employer did not furnish employment and a place of employment that was free from recognized hazards that were causing or likely to cause death or serious physical harm to employees in that employees were exposed to a…...

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Pressure Vessel Failure during Hydrotest – Nov. 2007, China

Pressure Vessel Failure during Hydrotest – Nov. 2007, ChinaPlease see the photos below of a pressure vessel that recently failed whilst under hydrotest during post fabrication testing. This vessel was manufactured by a vessel vendor in China and the plate was of Chinese mill origin. Unfortunately this is another example of serious equipment/material failures with…...

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Ammonia refrigeration processes below 10K MUST STILL meet ANSI/ASHRAE 15 Engineroom Ventilation

This is not the first time I have addressed this matter. Still, somehow, somewhere, a dirty little lie has been circulating among ammonia design and installation contractors that somehow an engine room handling less than 10,000 pounds of anhydrous ammonia (NH3) is incapable of presenting an explosion hazard, thus no need for any engineered ventilation. …...

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Relief Valve Maintenance & Testing

Some specialized literature regarding the maintenance of safety relief valves (SRVs) is available, but it is best to always consult the manufacturer’s detailed installation and maintenance manuals on the subject, as some type of valves might require special attention. It is highly recommended to always use genuine manufacturer’s spare parts. In some parts of the…...

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When the “Employee Participation” ain’t what its cracked up to be!

Almost all Occupational Safety and Health efforts need one key ingredient to be successful… Employees participating in the safety process!  Heck, OSHA and EPA have even regulated employee participation (EP) in their process safety standards.  But far too many organizations have not quite understood the concept of Parent-to-Parent engagement vs. Parent-to-Child engagement and almost all…...

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Bonding and Grounding of plastic containers during the dispensing or transferring of Class I flammable liquids (OSHA)

The requirements for bonding and grounding of containers during the transfer of Class I flammable liquids are contained in 29 CFR 1910.106(e)(6)(ii). This paragraph does not specifically address plastic containers. However, OSHA issued “OSHA Instruction STD 1-5.14-A” on October 24, 1980 to address plastic containers (NOTE: this STD is NO LONGER AVAILABLE via OSHA.gov). This…...

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Illinois EPA refers Ellinor Trucking to Attorney General for enforcement

Illinois Environmental Protection Agency Director has asked the Illinois Attorney General’s office to proceed with enforcement action against Ellinor Trucking and River Rock Logistics, operated out of Lanark. The Illinois EPA alleges an inadequate transfer hose was used when an Ellinor employee prepared to offload anhydrous ammonia to an above-ground storage tank, which resulted in…...

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Replacement in Kind… is it really?

Following the guidance of OSHA and EPA, the industry has attempted to simplify what type of change requires the initiation of the Management of Change system and which type of change is a “replacement in kind” (RIK).  Oddly enough, both OSHA and EPA chose not to define the meaning of “change”; instead, they have officially…...

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Safety Culture Maturity model – FSCMM (Fleming)

The elements that form the safety culture maturity model have been adapted from the safety culture components listed by the HSE in Reducing error and influencing behavior – HSG48.  It is unlikely that these elements will map precisely onto the factors that companies have previously measured in safety culture or climate surveys because there is…...

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Pressure Test gone bad! (Tank Launched)

On January 26, 2006, a factory in Brazil witnessed a significant accident during a pneumatic pressure test involving a tank and pipework. The incident occurred because blind flanges were not used to isolate the pipework connected to the tank. Instead, only the valves were closed. This oversight led to the possibility that one or more…...

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