Uninterruptible Power Supply (UPS) is a pretty common backup power supply in industrial settings where “power failure” can lead to the loss of control systems, emergencyshutdown systems, and emergency mitigation systems. But like ALL SAFEGUARDS we take credit for in our Hazard Analyzes, these UPS must be in our mechanical integrity program for testing/validation regularly…...
The assessment checklist below was developed by Dr. James Reason and presented at the 2000 Safety Conference. In Managing the Risks of Organizational Accidents, Dr. Reason argues that three (3) elements are vital for driving a company’s safety performance, all of them the purview of top managers: commitment, competence and cognizance The three Cs. But…...
Dr. James Reason’s checklist for assessing Institutional Resilience Read More »
“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to improve safety, several hundred accidents happen every year, and most such crashes are blamed on human error or outdated signaling equipment.”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…...
Active Failures vs. Latent Organizational Failures (India’s Train Wreck) Read More »
The establishment of a positive culture of safety within an organization is dependent on the following:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
How an organization goes about establishing its “culture of safety” Read More »
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…...
What does safety leadership LOOK and SOUND like from the C-Suite? Read More »
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…...
Don’t be confused as to OSHA’s role in an accident investigation Read More »
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…...
Not all biases are bad in safety; in fact one can be downright helpful Read More »
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…...
Is a public road considered a public receptor? Read More »
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…...
Is a double walled tank “passive mitigation”? Read More »
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?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
Maintenance requirements for leased tanks Read More »
Which states have been granted a delegation of EPA’s authority to implement and enforce the risk management program rule?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
States with authority to implement / enforce the risk management program rule Read More »
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…...
What is the definition of a “technically qualified individual”? Read More »
