NOTE: I have never managed a facility/workforce where we required Hi-Vis garments, except for Fire Watches and PRCS Entry Attendants, but those requirements were not for the user’s safety, so we did not get into all the ANSI requirements for these vests. However, I do equate this Hi-Vis effectiveness concern to what I dealt with regarding Flame Retardant Clothing (FRC) and its continued effectiveness. ...

This is another opportunity for facility sitting to apply specific metrics to the exercise. Just as the distances for Tank Truck and Rail Car Unloading/Loading facilities are intended to protect our bulk storage tanks, this is intended to prevent BLEVE(s) that could impact the above-ground storage tank. (emphasis by me) 1910.106(b)(2)(ii)(f) The MINIMUM SEPARATION between a liquefied petroleum gas...

In some cases, we can actually put specific measurements in our “facility siting” analysis.  Take, for example, an old but often missed distance between the tank truck/railcar and the closest aboveground tank.  (emphasis by me) 1910.106(e)(4) Tank vehicle and tank car loading and unloading. 1910.106(e)(4)(i) Tank vehicle and tank car loading or unloading facilities shall be separated...

At 7:30 p.m. on July 2, 2021, Employee #1, Employee #2, and Employee #3 performed two maintenance tasks in the M2 crude rectification section on the ground and second levels at tower M2-T250 and vessel V-207. On July 2, 2021, during the night shift, three (3) gas monomer chemical operators were exposed to toxic fluorocarbons and other hazardous chemicals while performing the maintenance tasks at M2-T250,...

We often refer to the ABC Model when discussing “Behavior Based Safety.”  ABC stands for Antecedent  ⇒ Behavior ⇒ Consequence An antecedent comes before a behavior and may trigger that behavior. A behavior is what/how the individual does an action. (good or bad). A consequence is something that follows the behavior (good or bad). So, an OSHA citation could be considered a “consequence”...

The Facility uses, handles, and/or stores more than a threshold quantity of ammonia (anhydrous), ammonia (concentration 20% or greater), and chlorine, which are regulated substances, as specified at 40 C.F.R. §§ 68.115 and 68.130. The Facility’s Cooling Tower 2 chlorine injection area contains up to 4,000 lbs of chlorine in two (2) 1-ton cylinders, above the chlorine RMP threshold quantity of 2,500...

A Health and Safety Executive (HSE) investigation into a gasoline overfill of a carbon adsorption vapor recovery unit (VRU) revealed concerns with the VRU’s design. The overfill prevention system was NOT INDEPENDENT of the basic process control system (BPCS).  When the BPCS failed, the overfill prevention system also failed. This resulted in loss of containment, and risked a significant...

We discipline for the behavior – NOT for the result/outcome of that behavior. This is never more true in safety-related events. When we discipline a worker for an injury for not wearing their PPE. We just set the standard for NOT WEARING PPE! So the next time a worker fails to wear their prescribed PPE, regardless of whether they were injured, the discipline is the same for the worker who was...

I believe the most significant challenge we (safety professionals) face is those outside (and even some inside) our profession and their lack of understanding of RISKS. I am confident that any safety pro reading this has endured the old and tired argument… “We have been doing ________ that way for __________ years, and it has not hurt anyone, but now you want us to do ____________?!?!?”...

Federal investigators determined a truck washing company failed to protect workers from hydrogen sulfide gas as they entered over-the-road tanker trailers to clean them out, causing one worker’s fatal injuries and hospitalizing two co-workers. OSHA responded to a report of the Sept. 1, 2023, incident and found the business failed to evaluate the tanker trailers for hazardous conditions –...

A boiler maker, 36, suffered fatal burns after an explosion occurred at a refinery. A contractor employed the victim and two injured co-workers at the facility. The three employees were hospitalized as a result of the explosion. The victim died four days later from burns over approximately 90% of his body. The events occurred in the area of the South Flare and Knock-Out Drum (KO Drum). A 36-inch pipe...

The dismissal of people and their behavior concerning risk as idiotic really doesn’t help much … HomeRead More »