Safety Info Posts

Breaking down 1910.120(q)(2) Written ERP requirements

HAZWOPER EMERGENCY RESPONSE PLAN DEVELOPMENT GUIDELINES(Elements of an Emergency Response Plan)1910.120(q)(2)  (i)  Pre-emergency Planning and Coordination with outside parties Facilities are required in the Superfund Amendments and Reauthorization Act (SARA) title III to coordinate their activities with outside response organizations and emergency response organizations. The emergency response plan (ERP) MUST address coordination with outside emergency…...

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Are there any RMP recordkeeping requirements?

Are there any recordkeeping requirements specified in the risk management program (RMP) regulations in 40 CFR Part 68? The owner or operator of a stationary source that is subject to the RMP regulations must maintain records supporting the implementation of Part 68 for five years (§68.200)…. Membership Required You must be a member to access...

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What is Error Management? (Reason, 1997)

Error Management (EM) has two (2) components: error reduction and error containment Error reduction comprises measures designed to limit the occurrence of errors. Since this will never be wholly successful, we also need error containment measures designed to limit the adverse consequences of those errors that still occur. At this general level, EM is indistinguishable…...

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Fostering the principles for a strong safety culture is one of the most challenging tasks facing a management team

Fostering the principles for a strong safety culture is one of the most challenging tasks facing a management team. Successful leadership achieving a strong safety culture will most likely move an organization to the next level of human performance. A leader is any individual who takes personal responsibility for his or her performance as well…...

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Where is your safety culture?

I have used this tool, with some modern-day modifications, for years.  When I was a safety manager of a facility I would constantly be looking for these indicators as a means to validate what I was “feeling”.  As safety pros, we have a sixth sense of how things are going, but there are so many…...

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Accountability, Culpability and a “Just Culture” (Dr. James Reason)

“Name, blame, shame, retrain” is an often-used phrase for older ineffective paradigms of safety management and accident analysis. Dr. Rosabeth Moss Kanter of Harvard Business School phased the situation this way: “Accountability is a favorite word to invoke when the lack of it has become so apparent.” Kanter, 2009 The concepts of accountability, culpability and…...

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

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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