OSHA has made significant changes to Chapter 4, The VPP Safety and Health Management System. Chapter 4 now requires VPP participants’ SHMS to consist of the seven (7) core elements described in OSHA publication 3885, Recommended Practices for Safety and Health Programs, October 2016, and in OSHA publication 3886, Recommended Practices for Safety and Health…...
Yes, this is a very OLD standard, but there is really nothing to replace it, as it still holds true today as much as it did in 2003. I have discussed this standard several times, and I ALWAYS share it with clients who are a tad lost on what the role of their safety professional(s)…...
SAFTENG NOTE 1: Two (2) of those being prosecuted were risk prevention technicians; one was a company employee, and one was a contractor SAFTENG NOTE 2: This silo explosion is very similar to the recent silo explosion in ME that took the life of a Firefighter Three (3) executives from an industrial wood processing and…...
We see this practice all across this great nation as we travel for our work. At most of the plants we visit, backing in is required. Recently, some HOAs took issue with homeowners backing into their driveways. Now I can not find the full story behind this issue with these HOA’s, but these viral videos…...
Back in 2021 – 2023, I spent time with some Class 1 Railroads attempting to help them develop and implement an SMS. During this time, I was impressed by the FRA’s Risk Reduction Plan (RRP), which required certain railroads to develop a written RRP and submit it for “FRA approval”. This was a massive step…...
My friend and one hell of a fine process safety guru in NH3 refrigeration, Brian Chapin, is always sharing this stuff with me. This is another great example of how correlation ≠ does not cause causation. Of course, this is the extreme, but I will bet many of us have seen correlation turn into causation…...
I wrote about “focusing on our fundamentals” this week, which generated a lot of discussions offline amongst my friends and clients. The number 1 question asked was “What should we score in 2026?” My response was “at least 95%”. That means that in 100 LO inspections, we should have a failure rate across ALL items…...
With all the noise in safety these days, I find it refreshing to just focus on the fundamentals and have management set targets on these fundamentals. For example, take a random safety walk on Monday and focus on Container Labeling. Count all the containers evaluated, count all the containers that were NOT labeled in any…...
The short answer is no. Radiographic Testing (RT) and pressure testing (Hydrostatic or Pneumatic) serve two (2) fundamentally different purposes in piping integrity. While it might seem like “over-testing,” they are not interchangeable in ASME B31.3 (Process Piping) or ASME B31.1 (Power Piping). Here is the breakdown of why 100% RT does not exempt you…...
We have a long-time client for whom we have now completed OSH and/or PSM/RMP audits at all of their North American facilities over the past 8 years. And this last audit was a “deal breaker” for many clients, as they were fit to be tied after the audit. Seems the facility had run its Safety/PS…...
One of my most debated topics at SAFTENG is my writings/ramblings about the critical role that a Management of Change (MOC) plays in ALL of safety, not just PSM. I’ve been involved in numerous non-PSM/RMP accidents that can be traced to poor or non-existent change management. One fatal event last year involved simply moving a…...
Don’t get me wrong, managers out in the plant wearing all the PPE and talking safety with their teams is a HUGE boost to safety (when it’s done consistently and well). I learned about “safety contacts” while at Great Lakes Chemicals in the mid-90s and used them at all my sites afterward. They have had…...
