In 2023, I began taking issue with the condition of Flame Retardant Clothing (FRC) being used in REQUIRED areas and tasks.  We see garments that in no way would pass a “routine inspection” per NFPA limitations.  My go to RAGAGEP for this is NFPA 2113, Standard on Selection, Care, Use, and Maintenance of Flame-Resistant Garments for Protection of Industrial Personnel Against Short-Duration...

A Health and Safety Executive (HSE) investigation into a gasoline overfill of a carbon adsorption vapor recovery unit (VRU) revealed concerns with the design of the VRU. 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 fire,...

OSHA’s PSM standard is over 30 years old, and EPA’s RMP standards/rule is approaching its 30th birthday fast.  They are so 20th century (LOL)!  This article is about how some of my clients are approaching their 3-year audits required by both standards.  This approach embraces the “audit element” of the process safety management system as genuinely intended: a...

If management believes safety is all about workers behaving as they have been trained, then we should be able to save thousands of dollars by ordering keyboards with no “delete” button. After all, if we expect workers to make no errors, mistakes, or violations in executing their jobs, we should have the exact expectations within management personnel carrying out their duties. We ALL make...

The value of a Root Cause Analysis and Corrective Action Plan process to a business If the critique process is effective and an organization successfully determines why the event occurred, the appropriate corrective action can be achieved. The avoided cost associated with recurrence and improvement in performance is the organization’s dividend. … HomeRead More »

Respondent owns and operates a chemical warehouse and repackaging facility. From November 2 through November 5, 2021, EPA performed an inspection of the Facility to evaluate compliance with Section 103 of the Comprehensive Environmental Response, Compensation and Liability Act (“CERCLA”), EPCRA Sections 304-312, and CAA Section 112(r). Based upon the information gathered during the Inspection and subsequent...

We have discussed the hazards of pneumatic pressure testing many times.  Pneumatic pressure testing should be a “last resort” for pressure testing process equipment.  But for those who question the degree of hazard this REQUIRED test brings about, here is something to consider.  Take a look at the following comparisons between the stored energy in piping systems and the equivalent...

Training is the backbone of WERTs and ESOs. Effective training produces team members and responders with the skills, knowledge, and confidence to safely perform their duties in the face of various hazards in emergency incidents. Paragraph (h) of the proposed rule contains requirements for INITIAL and FOLLOW-UP training for responders and team members and requirements for maintaining proficiency in...

Emergency response is a physically demanding occupation; approximately half of all firefighter on-duty and line-of-duty deaths are due to cardiovascular events. Emergency response activities can place a tremendous strain on the cardiovascular system, which can trigger a catastrophic cardiovascular event. This is especially true for team members and responders with pre-existing heart conditions, which...

The proposed rule would require Workplace Emergency Response Employers (WEREs) and Emergency Service Organizations (ESOs) to develop and implement a written comprehensive risk management plan based on the type and level of service(s) that would be established: Paragraph (c) Organization of the WERT, and Establishment of the ERP and Emergency Service(s) Capability and Paragraph (d) ESO Establishment...

To be effective, any safety and health program needs the meaningful participation of workers and their representatives. Similarly, for the Emergency Response Program (ERP) to be effective, team members and responders need to be involved in establishing, operating, evaluating, and improving the ERP. Team members and responders have much to gain from a successful program and the most to lose if the program...

Workplace Emergency Response Employers (WEREs) and Emergency Services Organizations (ESOs) respond to a wide variety of incidents, most of which are considered routine and involve a small commitment of resources. Some incidents are more complex and involve larger commitments of resources and potentially higher-risk operations. The WERE and ESO need to develop an incident management system (IMS) that...