Safety Info Posts

EPA RMP citations @ agricultural products facility (NH3 & $119K)

Respondent is the owner and operator of a facility that stores, manufactures, and distributes agricultural products, including anhydrous ammonia. The threshold quantity for anhydrous ammonia, as listed in 40 C.F.R. § 68.130, is 10,000 pounds. On or about August 22-23, 2023, a representative of the EPA conducted an inspection of the Respondent’s Facility to determine…...

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When you see it… Bollards and Gas Meter

As many of you know, I have a love of bollards. This love has come over many years and many accidents where I have seen them protect a critical asset and PREVENT a serious event. This is a new county building built near my home, and when I drove by, I had to take a…...

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Incident Commander Training clarifications

Is it OSHA’s intent that Incident Commanders be 24-hour HAZWOPER trained irrespective of their actual working location during an incident, e.g., if they are located off-scene, outside of the contaminated area or far from the incident, and are never actually exposed to the site hazards?  OSHA’s HAZWOPER standard does not vary the required training for Incident…...

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Safety Thought of the Week… James Reason’s Human Failure Model

James Reason’s Human Failure Model: Active and Latent [Organizational] Failures As safety professionals, we need to understand that we ALL make errors, mistakes, and violations. When we are asked to facilitate a causal analysis, it is incumbent upon us to keep the team aware of this fact and educate them on the differences between Active…...

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Days worked w/o injury and Pizza Parties (Comedy Skit)

This is one of my favorite videos to use in my SMS Training courses (with approval from HR). Some of the scenes are over-the-top fake graphic scenes, but they are so over-the-top that I hope adults can handle them. The video mocks Lagging Indicators and Pizza Parties, which most of us have come to recognize…...

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My favorite SMS Element to use as a “kick-off” is Incident Management

As SAFTENG wraps up another successful year, I am reminded of its success. I got a thank you note from a facility manager who hired us to build an SMS/Safety Process to “bring some sense to safety.” He and his team were tired of the ups and downs and wanted consistency in their performance with…...

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My favorite SMS Element to use as a “kick-off” is Incident Management Read More »

The myth that a “Culture of Safety” does not exist

I have to chuckle when companies and experts tell me there is no such thing as a culture of safety. That there is only one culture (if even that). I call bullshit on that belief. One way to learn this is the hard way, such as what Boeing is going through.  And on an investor…...

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The use of a Lockout Hasp is NOT “group lockout”

I will probably catch a lot of flack for repeating this (as I have this debate at least annually), as very few agree with me, but it needs to be repeated!  The use of a Lockout Hasp, the device shown to the left, is NOT associated with the phrase “group lockout.” And yes, I am…...

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Safety Thought of the Week (Richard I. Cook, MD)

Complex systems contain changing mixtures of failures latent within them The complexity of these systems makes it impossible for them to run without multiple flaws being present. Because these are individually insufficient to cause failure they are regarded as minor factors during operations. Eradication of all latent failures is limited primarily by economic cost but…...

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Personal gas meter, its placement, and our “breathing zone”Ha

If we spend enough time in chemical plants, we will encounter a widespread, albeit severe, human failure regarding a “safety-critical instrument.”  I am referring to the IMPROPER placement of personal gas monitors.  Nine times out of 10, where do we find these personal gas monitors on the worker’s body?  I am betting your experiences are…...

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EPA’s RMP Emergency Drills vs. International Fire Code Drill Requirements

The EPA’s revisions of its Risk Management Plan requirements regarding emergency drills have gotten much attention.  However, they were always a bit behind when it comes to the International Fire Code.  And need I remind those of you reading this that many states have adopted the IFC in some form. A Group H occupancy is…...

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OSHA reiterates the 15-minute flow requirement for eyewash stations

In a 2024 LOI, OSHA reiterated its position that an Eyewash (EW) station must be capable of delivering 15 minutes of water flow. This means these EW bottles are NOT an “approved” EW station. Even the double barrel wall mount with two (2) squirt bottles does not meet the minimum flow rates. However, OSHA has…...

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