A worker died of acute hydrogen sulfide (H2S) poisoning while responding to an alarming water pump involved in the process of extracting crude oil and natural gas. The worker was alone in the pump house, attempting to close process valves to isolate the pump. The pump unexpectedly energized either before the worker’s arrival or during his work, releasing water containing H2S gas into the pump house. ...

The Respondent operates a frozen poultry storage facility. The Facility is located within several hundred feet of residences.  Respondent uses 15,900 pounds of anhydrous ammonia in a refrigeration “process,” as defined by 40 C.F.R. § 68.3, in a system of pipes and vessels at the facility (the “Process”).    On June 6, 2019, EPA inspectors visited the facility...

The Emergency Planning and Community Right-to-Know Act (EPCRA) establishes requirements for federal, state, and local governments, Indian tribes, and industry regarding emergency planning and reporting on hazardous and toxic chemicals. Individual facilities are required to conduct emergency planning with state and local emergency planning committees, report accidental releases to the proper authorities,...

When a manufacturer or importer ships defective/rejected Li-ion batteries for disposal or recycling, they are required to provide an HCS-compliant SDS to downstream employers. An HCS-compliant label would not be required for a product that is regulated under the CPSC.7 For example, consumer products that are generally regulated by the CPSC include button cells (e.g., watch batteries), small batteries...

This [Portable] Rechargeable Battery Association (PRBA) inquiry includes a number of scenarios and questions raised by its members related to the article determination, hazard classification, consumer product exemptions, and labeling requirements The PRBA scenarios and questions have been paraphrased, followed by our responses. In addition, Attachment 1 to this letter provides several scenarios to...

Once again, I can not stress how valuable FM Global can be to your safety efforts.  Their Loss Prevention Data Sheets are FREE and some of the best guidance we can find.  Our profession is always complaining about spending money on ANSI, ASME, NFPA, etc. codes and standards. Yet, these Loss Prevention Data Sheets are FREE, so there is no excuse for not utilizing these documents to improve...

For most senior safety professionals, we have arrived at a place in our careers where we can understand the significance of what Dr. Reason said in 1997.  Although most would agree, we started our careers in a very different place when it comes to how we derived the root causes of accidents throughout our careers.  But when Dr. Reason stated this in 1997, it was not well received; especially...

The significance (or severity) of an event depends upon the consequences suffered and not on the error that initiates it. The error that triggers a serious accident … and the error that is one of hundreds with no consequences… can be the same error.   Human Error, James Reason, Department of Psychology University of Manchester, 1990

Now keep in mind this is a child in the video.  But that does not mean adults would not do something similar after watching a co-worker successfully pull it off!  After all, MOST, if not all, unsafe acts are learned actions from co-workers.  So watch this short video, as painful as it may be to some, and answer the question, is this an Error, Mistake, or Violation using Dr. James Reason’s...

Your OSH or PSM/RMP audit report declares a human factor issue was found. You honestly wonder how much of a risk this really is, but you’re told it has to be fixed so we can close out the finding. So I present to you HF Engineering 2023 … HomeRead More »

Maybe I’m just old school, but is it just too much to ask for: a well-written safety procedure, one that is written and analyzed with a safety pro and the worker(s) who do the actual work, that management will fully support the procedures everyday-everytime, including on holidays that fall on a Sunday, and employees will follow procedure everyday-everytime, including on holidays that fall on a Sunday?...

I thought I had shared this image before, but I could not find it. I did NOT create this image but have had it since 1994. It came from my first HF Engineering Course in preparation for Process Safety, specifically the HFA part of a PHA. … HomeRead More »