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I am proud to announce that SAFTENG and The Chlorine Institute have renewed our partnership for another year (through 2026).  Members of The Chlorine Institute receive a FREE SAFTENG membership.  If you qualify, please contact me

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Li Battery Storage ideas (compartmentalizing our risks)
Throughout my career, I have been called “crazy,” “certifiable,” “unreasonable,” etc. I have worn those insults as a badge of honor, as in my professional opinion, there is nothing too crazy to protect the men and women doing the dirty and dangerous work! So buckle up, as this thought process may push you over the edge in how we could manage these high-energy batteries…...
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Accidents, their cost, and traffic jams caused by accidents
Many safety pros struggle to get management to understand the “indirect costs” of accidents. This is a real cost to the business, but those outside our profession are so far outside that they struggle to grasp the “indirect cost.”  Heck, many fail to grasp the “direct costs” since they do not come out of their pay. Most of us have heard the phrase, “It...
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James Reason Human Failure Model Flowchart 2023
When/if the time comes when disciplining worker(s) is needed for safety, just remember: CONTEXT is everything!
I was recently involved in a safety review at a client with two (2) separate LOTO failure events in a month.  I know this client and the PM very well, and I was never more disappointed in their decisions about the discipline around these two (2) very different LOTO events.  One event resulted in NO injury, and that employee received no discipline; the other event injured two workers (both...
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Class 2 Div 2 sign
HAZLOCs and Labeling
Based on the feedback from other SAFTENG members, I have made this article public for the next 30 days. Much like the process safety debates around valve/equipment labeling, no RAGAGEP specifically requires a unique identifier on every valve or piece of equipment. Yet, labeling valves/equipment within the covered process is necessary to manage the process’s safety.  Another debate we have...
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Determining if an employee’s death would be work-related when involved in a motor vehicle accident
Scenario: In your letter, you state that an employee who does not have a fixed work site left his home and traveled approximately 300 miles to a customer site. After the employee arrived at the customer site, he checked into a hotel and conducted work activities for several days. Once the work activities at the customer site were completed, the employee traveled to a relative’s home and stayed...
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Using the PLAN-DO-CHECK-ACT model to ensure the Heat Injury and Illness Prevention Plan is being implemented and risk are being managed
Recently, a client had two (2) heat-related incidents within one (1) week.  This after, we forced a download of the OSHA/NIOSH Heat App to all company phones.  I have used this technique to ensure front-line supervisors and managers have a TOOL to help them manage the Heat Prevention Plan requirements.  I have used this forced download several times, and the results vary wildly. ...
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National Enforcement and Compliance Initiative: Chemical Accident Risk Reduction (2024)
EPA has found that major chemical accidents continue to occur from facilities that are not adequately managing the risks they pose to ensure the safety of their facilities and protect surrounding communities. Many of these communities have environmental justice concerns or face climate change-related hazards or both. Thousands of facilities nationwide make, use, and store extremely hazardous substances....
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UPDATED: Why are industries exempt under OSHA's PSM subject to RMP?
The Program 3 prevention program requirements under 40 CFR Part 68 are almost identical to the requirements of OSHA’s process safety management (PSM) standard. OSHA exempts certain industries from the PSM standard. Why does EPA not exempt those same industries from the CAA §112(r) risk management program requirements? … HomeRead More »
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Does the distance to endpoint start at the process or stationary source boundary?
When selecting the worst-case release scenario for Program 2 and 3 processes as required by 40 CFR §68.25, a stationary source owner or operator must analyze the release scenario that results in the greatest distance to an endpoint. Does the “greatest distance to an endpoint” refer to the greatest total distance from the process (e.g., vessel or pipeline), or to the distance beyond the...
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OSHA PSM citations @ Food plant (NH3 & $64K)
The alleged violations below have been grouped because they involve similar or related hazards that may increase the potential for injury or illness. … HomeRead More »
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The SIF debate is alive and well in the EHS community
For me, SIF is just using Process Safety Management (PSM) tools for lower-frequency, higher-severity events, whereas traditional “recordable injuries” can be managed with the traditional Safety Management System (SMS). But here is the catch… the consequence may be more severe (serious), but the failures that led to those consequences can all be traced back to the failure of our Controls/Barriers/Safeguards...
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Safety Thought of the Week & more defending of H.W. Heinrich's work
Heinrich did not blame workers for accidents—quite the opposite. He was more in the camp of Latent Organizational Failures, as James Reason taught us in the 1980s. In this passage from his 1928 article “The Origin of Accidents”, Travelers, we can see his position on accidents on full display… Remember, he said this 96 years ago!!! … HomeRead More »
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