Respondent is supplied with raw chemical feedstocks by tanker truck or railcar. Chemical unloading operations occur on the eastern portion of the Facility at dedicated tank truck and railcar unloading stations. Several chemicals are stored in bulk at the Facility in dedicated aboveground storage tanks (ASTs), including, nitric acid (one tank), hydrogen peroxide (four tanks), sodium hypochlorite (two...

Respondent operates a granular monoammonium phosphate (GMAP) process and a diammonium phosphate (DAP) process at the Facility, meeting the definition of “process” as defined by 40 C.F.R. § 68.3. A different Respondent operates an anhydrous ammonia process at the Facility, meeting the definition of “process” as defined by 40 C.F.R. § 68.3. The GMAP and DAP processes are located on contiguous property...

I am teaching my 3-Day Intermediate Process Safety course this week, and one of the popular exercises we do on Day 1 is the “Vehicle Safety Challenge.”  It is designed to teach students to begin thinking about Layers of Protection within the PREVENT-PROTECT-MITIGATE model.  Five students in four (4) groups have 15 minutes to … HomeRead More »

The good old “safety incentive program” has been around since man walked upright and has been misleading management since its conception.  The concept is valid, based on the old “carrot and the stick” model.  There has always been one fatal flaw in these programs… they usually incentivize the WRONG things!  The traditional safety incentive programs, many...

One of the top questions we get regarding contractor safety is, “Do I have to evaluate, orientate, and audit subcontractors working for a contractor we hired?”.  OSHA’s latest revision of their PSM CPL answered this question. Is the host employer of a PSM-covered facility responsible for the safety of subcontractors? … HomeRead More »

The NSW Resources Regulator has published a fact sheet on its human and organizational factors data review.  The Regulator engaged the Keil Centre to independently review its human and organizational factors analyses over the past five (5) years, where HUMAN ERROR and DELIBERATE NON-COMPLIANCE played a role in incidents.  The review looked at 267 incidents at 180 at surface mines and 87 at...

Responding to a report of workers being exposed to anhydrous ammonia, federal investigators found a Madison ice cream plant lacked sufficient process safety management procedures to control the release of hazardous chemicals.  Investigators with the U.S. Department of Labor’s Occupational Safety and Health Administration determined the Ice Cream facility failed to document that equipment was being...

On December 14, 2023, OSHA published its revised Compliance Directive for Process Safety Management standard 1910.119, effective January 26, 2024. This new version is in Q7A format and was done nicely, although there are a number of things in the answers that I am sure will be challenged.  I have highlighted some of the interesting (albeit I believe the correct answer).  For example, QA-31...

HOP is NOT an Element of a Safety Management System (SMS) HOP principles are HOW we manage our SMS   We see a lot of discussions on social media regarding the role of HOP and Psychological Safety, two methods I fully embrace should be used in OSH and PSM. However, I view these two methods as HOW I manage my safety management system (SMS), and they do NOT replace my SMS (as some “experts”...

Let’s talk about DE-incentivising businesses to properly manage Occupational Safety and Health (OSH), even at the most basic level. OSHA now requires businesses to report their injury and illness logs, which they will use to identify workplaces needing a compliance inspection. They are doing this due to their lack of adequate resources, and they want the businesses and industries to self-report...

Sweating the “small stuff” matters in process safety management.  Meeting the details of our chosen RAGAGEPs matters!  Although I am often told, “That is a picky audit finding,” it is what it is.  Far too many facilities believe that designing their process piping to be bolted flange assembly vs. welded joints is somehow easier; in some ways, it is more difficult. ...

We have discussed the critical role of “torque” in constructing our chemical processes.  I catch a lot of flack for my insistence on this critical function, for which I am genuinely surprised.  But our piping design and construction RAGAGEP (ASME B31.3) is pretty clear on the matter, and now OSHA and EPA have “caught on” and are issuing citations where there is an...