First, let’s define what this article is all about.  Has your facility ever had a leaking flange?  Just a tiny drip of liquid or a small release of gas?  What is the most common response to this leaky flange?  Someone goes out and tightens the flange bolts to stop the leak.  This practice is done in the process industry hundreds of times a month in large facilities, and...

Under the Clean Air Act, Section 112(r), the EPA established a program requiring facilities possessing greater than certain threshold quantities of 140 chemicals to provide risk management plans to the EPA.1  As part of this reporting requirement, facilities are required to determine the worst-case scenario release from a single chemical process, using EPA criteria and guidelines.2 Facilities...

RMPs MUST be updated at least once EVERY five (5) years. Owners and operators responsible for RMP implementation should review the factsheet A Checklist for Submitting your Risk Management Plan (pdf). This factsheet provides a checklist to consider in updating and resubmitting RMPs. Use EPA’s RMP*eSubmit for your resubmissions. For additional information see the RMP*eSubmit Users’...

It cannot be assumed that workers will naturally begin to report problems, errors, and near misses once a just environment is in place. There are a number of organizational as well as psychological barriers that must be hurdled before a reporting culture can be put in place.   The first barrier to overcome is … HomeRead More »

In older facilities, we see illumination for an exit sign coming from an external source.  Section 1013.6 of the IBC regulates the graphics, illumination, and emergency power supply for such signs. Although no particular color is specified for exit signs, it is REQUIRED that the color and design of the signs, the lettering, the arrows, and other symbols on the sign provide good contrast to increase...

Dr. Sidney Dekker (Ph.D. in Cognitive Systems Engineering) states there are basically two (2) ways of looking at human error. In this article, I share with you, the first view, which could be called “the bad apple theory“. It maintains that: … HomeRead More »

Three (3) ingredients are vital for driving the safety engine, all of them the province of top management or what the organizational theorist, Mintzberg, has termed the strategic apex of the system. These driving forces are: commitment, competence and cognizance Reason’s three C’s. … HomeRead More »

Take any of the following steps below that may be necessary to guard against stored energy(s) left in the equipment after it has been shut down and isolated from its energy source(s). … HomeRead More »

An older post, with updates…Ever since the 2005 BP Texas City tragedy, refineries and chemical plants have been working diligently to review “facility siting” risks for their facilities.  As with all of the PSM elements, many of us took this new focus as a learning opportunity.  We had all done something we called “facility siting” in our Process Hazards Analysis, but in the early 1990’s...

Key Principles in integrating Human Factors in Hazard Identification, Hazard Analysis, and Risk Assessments include: … HomeRead More »

As we have discussed here many times, our piping is our “primary containment” that seems to be where the vast majority of Loss of Primary Containment (LOPC) events occur. Many reasons for this, which we have spelled out in other postings, but none the less the vast majority of “leaks” occur in our piping. One means that we should be abiding by is “proper support”...

March 31, 2009 MEMORANDUM FOR:     REGIONAL ADMINISTRATORS THROUGH:        DONALD G. SHALHOUB DEPUTY ASSISTANT SECRETARY   FROM:                RICHARD E. FAIRFAX, DIRECTOR DIRECTORATE OF ENFORCEMENT PROGRAMS  SUBJECT:          Management of Organizational...