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Human Factors - Failed Checklists
Northwest Airlines Flight 255, a McDonnell Douglas MD-82, crashed in Romulus, Michigan, shortly after takeoff from Detroit Metropolitan Wayne County Airport on August 16, 1987, at about 8:46 p.m. It killed all six crew members and 148 passengers, and two people on the ground. There was only one survivor, it was a 4-year-old girl who sustained serious injuries. It was the second-deadliest aviation...
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CFATS by the numbers on its 15th Anniversary
November 20, 2022 was the anniversary of Chemical Facility Anti-Terrorism Standards (CFATS) regulations.  And although it is not as well known as OSHA’s PSM and EPA’s RMP standards, it is a standard that many PSM/RMP practitioners deal with, so I thought it would be fitting to look at the CFATS numbers… … HomeRead More »
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EPA offers insights into "Responding Facility" vs. "Non-Responding Facility"
In a recent training course, the EPA answered the “One Big Question”… (one that I have written about many times) Does the facility rely on emergency responders to stop the release of the regulated substance(s)? If the facility answers Yes, they are saying the local first responders will respond and stop the release.  This means the facility is responsible for the following: Comply...
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EPA RMP triggers to have your case referred to DOJ
Here are the six (6) triggers that will get your RMP Inspection Case referred to DOJ: … HomeRead More »
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Fish holds on commercial fishing vessels (H2S)
This Safety Alert addresses the importance of verifying atmospheric conditions in fish holds on commercial fishing vessels. There are specific hazards associated with the use of brine dip solutions, a common substance used in the industry. Brine dip combined with standing water can produce dangerous levels of hydrogen sulfide (H2S). The U.S. Coast Guard is currently investigating a marine casualty...
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Human Factors is Humans making decisions
Human Factors means HUMANS making decisions- OUR roles as safety professionals is to chart a path to SUCESS IN SAFETY, rather than hoping they avoid failure. Safety is NOT about luck. Safety is the confidence that there is a path to safety success – CULTURE is convincing the workers that the best path is the path to THEIR safety success. … HomeRead More »
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Human Factors 101... chartering a path for safe decisions
Human Factors mean HUMANS making decisions- OUR role as safety professionals is to chart a path to SUCESS IN SAFETY, rather than hoping they avoid failure. Safety is NOT about luck, safety is having the confidence that there is a path to success – CULTURE is convincing the workers that the best path is the path to THEIR safety success.
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EPA RMP Citations @ olefins facility (Flammables & $9K w/ $43K SEP)
Respondent is the owner and operator of an olefins facility which had two (2) incidents that occurred on December 20, 2021, and May 3, 2022, that resulted in accidental releases. Respondent has an olefins unit process at the Facility, meeting the definition of ” process”, as defined by 40 C.F.R. ยง 68.3. EPA Findings of Violation … HomeRead More »
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Active vs. Latent Failures
A comparison of the characteristics of active and latent failures suggests that avoiding active failures tends to drive down the frequency of events while finding and rectifying the results of latent failures tends to drive down the severity of events. … HomeRead More »
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Progress of Decline
The decline of a safety culture
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A lot of OSHA standards follow the SMS protocol
Whether we recognize it or not, many of the OSHA standards follow the principles of a well-grounded Safety Management System (SMS) that includes: Hazard Identification Hazard Analysis using a recognized methodology Risk Assessment so that risk can be quantified and put into perspective Risk Mitigation using the Hierarchy of Controls (Elm, Sub, Eng, Adm, PPE) Take, for example, OSHA’s Permit-Required...
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So many first steps in OSH turn out to be trips and falls
In occupational safety and health, there are a lot of opportunities for businesses to stumble and fall right out of the gate. Although many folks like to claim “anyone can do safety,” this myth drives these mistakes. Untrained/Uneducated persons are attempting to manage an OSH program and stumbling at step one, leaving hundreds/thousands of employees at untold risks. Take, for example,...
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