OSHA clarifies HAZWOPER training requirements for on-scene Incident Commanders and other positions in the Incident Command System (ICS) and whether previous non-HAZWOPER training can be credited toward the training required by HAZWOPER for Incident Commanders.  Here are the four (4) questions OSHA discusses: Is it OSHA’s intent that Incident Commanders be 24-hour HAZWOPER trained, irrespective...

A client recently underwent an RMP inspection by the US EPA.  One of the issues the inspector took issue with was that the facility did not “certify” their 3-year audit.  This stems from the following: (emphasis by me) EPA RMP § 68.79 Compliance audits(a) The owner or operator shall CERTIFY that they have evaluated compliance with the provisions of this subpart, at least every...

It is 2024, 32 years after OSHA passed its Process Safety Management of Hazardous Chemicals standard. I am fortunate to have clients who have progressed in their PSM maturity, and we spend a lot of time these days working to get other processes into the PSMS. We start with processes that are not covered because their maximum intended inventory is managed to keep them BELOW the standard’s TQ....

This ONLY applies to Michigan workplaces, but it was such a weird way to enforce the PRCS standard that I thought it was worth sharing. Keep in mind that more than 50% of PRCS deaths are “would-be rescuers.” Rescue Operations MIOSHA has no authority to direct rescue operations.  This is the responsibility of the employer and/or of local political subdivisions or State agencies. MIOSHA...

This rulemaking requires the Air Conservation Commission to develop a state rule and accept delegation from the EPA. This rulemaking will lay the groundwork for the Agricultural Anhydrous Ammonia RMP Compliance and Enforcement program. Once delegated, the oversight for the RMP program will transfer from EPA to DNR. The benefit of this rulemaking affects the agricultural community in the State of M...

The Occupational Safety and Health Administration (OSHA) issued a Request for Information (RFI) on December 9, 2013 (78 FR 73756). The RFI identified issues related tomodernization of the Process Safety Management standard and related standards necessary to meet the goal of preventing major chemical accidents. OSHA completed SBREFA in August 2016. OSHA held a stakeholder meeting on October 12, 2022,...

You can assess your own health and safety management system using this self assessment checklist (.doc) . Use the columns in the middle of the table to give yourself a score for each element.  Where you give yourself a score of 1 or 0 you may need to take action to improve those elements – note this in the right hand column. Where you award yourself a score of 2 it means you are doing well. If...

All changes to an organizational structure or changes in personnel with specific Knowledge, Skills, Experience, and Behaviors (KSEB) must be assessed to understand the impact of the organizational change on safety. Any organizational change has the potential to introduce safety hazards and risks, and therefore, all changes to an organizational structure or changes in personnel with specific KSEB must...

The systematic process to manage any change should follow the “Plan, Do, Check, Act” approach. This should start at the planning stage BEFORE: the change has been fully developed, continued and monitored during the change process and reviewed after it has been implemented. This systematic approach applied to all changes to equipment, infrastructure, policy, or the organization must include:...

Although this advisory circular is for Commercial Human Space Flight, it can be applied to High-Risk activities in an industrial setting, such as process safety matters. The single most significant gap I see in past PHAs is the Human Factor(s) analyses. In some cases, I cannot even recognize the methodology used in the PHA. In the year 2024, it is about time we begin to take the HF analysis and the...

How much time does the owner or operator of a stationary source have to submit a correction to a Risk Management Plan when the emergency contact information changes? … HomeRead More »

It is suggested that LATENT ORGANIZATIONAL failures are analogous to the “resident pathogens” within the human body, which combine with external factors (stress, toxic agencies, etc.) to bring about disease. Like cancers and cardiovascular disorders, accidents in complex, defended systems do NOT arise from single causes. They occur through the unforeseen (and often unforeseeable) concatenation...