All this talk about “Sh_t That Can Kill You” (STCKY) and focusing on those Low-Frequency, High-Severity risks is just one of the current safety fads. I like SIF, and if you really think about it, SIF and Process Safety are very much aligned. But I have never understood why it needed to be its own little program, with all this PR virtue signaling; other than to make some consultants a lot...

In my experience, I have come to understand two (2) SMS/PSMS elements need to be first in line for development and implementation, as these two (2) elements are critical in the early days of developing and implementing a formal/structured SMS/PSMS. What would your two (2) elements be? My two are: … HomeRead More »

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…...

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...

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...

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...

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...

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. ...

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....

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 »

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...

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 »