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Since 2015
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Culture of reporting and LEARNING from our mistakes
An organization that listens to and learns from its people is constantly improving and understands that mistakes, errors in judgment, and the need to adapt are normal.  Organizations should listen to and support their personnel by promoting a culture that: Encourages them to report mistakes and safety occurrences and Investigate them where appropriate. When an organization is listening and learning...
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Quality Assurance Risk-based Approach in a Safety Process/SMS
A risk-based approach means focusing assurance efforts on the activities and controls that give rise to the most significant safety risks that may impact the successful delivery of the Organization’s objectives. It can also include focusing assurance in areas where the most benefit will be derived from the effort. This means a high-level prioritization approach to identifying, assessing, reporting,...
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Russian BLEVE @ Gas Station (10/2024 Videos)
A BLEVE at a gas station in Russia killed at least four (4) people. Several excellent videos have been shared with our membership and me.
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Scrubber under N2 blanket kills entrant
On February 19, 2015, employees were to perform a preventive maintenance inspection inside of a scrubber, which is maintained free of oxygen using a nitrogen blanket. When the designated attendant could not find the entrant employee, other employees searched for him. The entrant employee was found inside the scrubber (a metal tube) where he had been preparing to clean it out. He was found to be unresponsive....
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Improper "cleaning" of the process leads to 16 workers being treated and released (bromo acetone and hydrogen bromide)
The process in progress at the time of the event was the manufacture of methatrexate, an anti-cancer drug. Shortly after employee #1 began to draw bromine liquid into the supposedly clean and empty charging pot, he heard a hissing sound. He then saw a purple haze spewing out from under the lid of the pot. Analysis of the residue left behind inside the charging pot showed that bromine had reacted vigorously...
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Modified_EXFV
Lack of Training and Poor labeling of Emergency Shutdown Button, and an altered excess flow valve leads to serious event
When we use the phrase “cascading failures,” this event is nearly a perfect example.  1) A gas station employee attempted to fill a propane tank without the required training. This led to the uncontrolled release of approximately 1500 liters (396 gallons or 1,600 pounds) of liquid propane and evacuated nearby homes. 2) When the staff went to use the emergency shut-off, poor labeling resulted...
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Failure to PROPERLY pressure test, leak test, and purge gas lines after testing leads to NG explosion @ fruit orchard
An explosion occurred inside a mobile trailer containing five (5) gas-fueled clothing dryers at a fruit orchard and processing facility. The blast caused damage to the building, and the facilities manager, who was inside when it took place, received burns and contusions. In 2019, the gas-fueled clothing dryers were installed and converted from natural gas to propane by unqualified individuals...
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Hazards of filling PIT LPG cylinders (Hydrostatic RV w/ INCORRECT Set Point)
In recent years, we have seen many facilities begin to fill their own PIT LPG cylinders on-site rather than contract this service out. Typically, we find this “change” was poorly managed: no PPE Hazard Assessment, no (or very poor) training on the task, LPG improperly located, improper electrical classification around the LPG tank and the filling station, etc.  This comes down to management...
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Is Caustic (NAOH) in your Line/Equipment Opening SWP? ($121K in OSHA citations)
During my time in the process industry, we usually had a “caustic scrubber” attached to our PSM/RMP covered process(s).  This meant this scrubber was “part of” the covered process.  I get a lot of pushback regarding covering “safety critical utilities” that are in place to either PREVENT, PROTECT, or MITIGATE an event from the covered process, but for me,...
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Line Break gone bad? (High pH solution and Verifying ZES w/o gauge)
We routinely discuss the challenges and risks of performing Line/Equipment Opening (LEO) tasks, with one of the top 5 challenges being the “means used to verify” the pipe/equipment is at a Zero-Energy-State (ZES).  The factors that occurred in this incident probably happens by the hour in the process industry; it is why we ALWAYS have on a layer of PPE that will protect us when this...
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1998 H2S incident (same contractor; wrong place-wrong time)
Looking at the contractor involved with the refinery H2S incident last week, I came across another refinery accident involving H2S where this contractor had their employees exposed.  I have no special info on this latest incident, and I will let the media release the name of the contractor, but this 1998 incident was being in the wrong place at the wrong time.  Another contractor company...
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Inspection Guidance for Animal Slaughtering and Processing Establishments
October 15, 2024 MEMORANDUM FOR: REGIONAL ADMINISTRATORS STATE DESIGNEES THROUGH: AMANDA L. EDENS, Deputy Assistant Secretary FROM: SCOTT C. KETCHAM, Director Directorate of Enforcement Programs SUBJECT: Inspection Guidance for Animal Slaughtering and Processing Establishments This memorandum establishes guidance for inspections conducted in all animal slaughtering and processing establishments, North...
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