One of the top questions we get and it goes to HAZARDOUS MATERIALS MANAGEMENT!  We have an EHS/HHC on site and today we are under the PSM and RMP TQ’s – KEEPING in mind that the standards have different TQ’s for many of the EHS/HHC’s.  But if we do not manage these inventories AND cap the amount we allow on-site, we will get burned one day and I do not mean in the...

I have had seen dozens of facilities covering (albeit very poorly) a process that is NOT a PSM/RMP covered process because some consultant told them it was.  The consultant(s) would point to an old statement by EPA that the Threshold Quantity (TQ) determination was based on the process’s ability to hold an amount exceeding the EHS TQ(s).  This was grossly incorrect and just this year...

EPA attempts to define and quantify how far apart do separate vessels have to be – to be considered different processes? … HomeRead More »

Yes, I’m well aware that EPA has officially stated that an Org Chart showing who is responsible for the various elements is all that is need to “comply”.  But in an actual functioning process safety management system, we will not only define who is responsible for each element but we will also explain HOW each element will be managed.  99.99% of the written programs we see...

We have all been there… the auditor identified several “physical changes” during their walk-thru of the process, and when it comes time to audit the MOC element, they begin asking for completed MOCs (and PSSRs).  And like everyone before us and mostly after us, we will have made changes that needed a MOC, but we failed to perform one.  This leads to an audit finding and...

OSHA’s and EPA’s process safety standards require a lot of specific training in order to meet their minimum compliance requirements; however, in this article, I want to point out that although OSHA or EPA makes no specific mention of this training, the training is ABSOLUTELY NECESSARY for a functioning process safety management system. … HomeRead More »

A central Illinois grain-handling cooperative exposed workers to serious engulfment hazards when soybeans collapsed inside a bin and engulfed an employee up to their waist.  An investigation by OSHA found that two workers were clearing the bin of crops and debris when the February 19, 2021, incident occurred. OSHA proposed $303,510 in penalties after identifying three (3) willful, one (1) serious,...

A worker at a milk packaging plant operated by a large supermarket chain lost four fingers while operating a molding machine that lacked the required safeguards.  OSHA investigated the Feb. 12 incident and cited the business for two (2) willful and five (5) serious violations and one (1) other than serious violation for: Failing to implement procedures for the control of hazardous energy, including...

Corrective action and change management programs secure the proportionate, prioritized close-out of actions arising from monitoring, investigations, audits, and safety management system reviews. Taking from the “Five Themes for Excellence in Safety Management Systems (SMS),” we can look at a facility’s approach to its Corrective Action Plans (CAP) process through this lens of excellence...

Oregon OSHA has fined a custom crush winery in Dundee $11,100 for violating job safety standards designed to protect workers from the hazards of confined spaces.  The division cited the winery following an investigation into the death of a worker.  The investigation found that at approximately 10:30 a.m. Feb. 1, 2021, a cellar worker was discovered unresponsive in an empty 30,000-gallon wine...

When trying to assure that people will work in a safe environment, it is imperative to understand how a building is intended to be used. The code classification system for buildings is therefore based upon how the building is intended to be used. The safety of building occupants cannot be assured if only the construction type and the height and area of a building are considered. How a building is used...

Call me crazy, but this just blew me away.  And once again we find ourselves faced with an “industry practice” vs. “RAGAGEP”.  We were at a facility several years ago where pieces of equipment are painted and this painting is a huge pride of the manufacturing sector and hence they have some very tight QA controls around the painting process.  This industry uses...