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De-enerizing Stored Energies
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 »
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A reverse look at Facility Siting and Change Management
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...
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Key Principles in integrating Human Factors in Risk Assessments
Key Principles in integrating Human Factors in Hazard Identification, Hazard Analysis, and Risk Assessments include: … HomeRead More »
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IMC Table 305.4
PSM and RMP (e.g HAZMAT) Pipe Supports... how many and how far?
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”...
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Management of Organizational Change (OSHA Letter to RAs)
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...
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The strategic approach to improving Human Performance
The strategic approach to improving human performance within safety embraces two (2) primary challenges: Anticipate, Prevent, Catch, and Recover from ACTIVE errors Identify and Eliminate LATENT organizational weaknesses that provoke human error and degrade controls against error and the consequences of error Preventable errors will not be eliminated if opportunities to err are not methodically identified....
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EPA Can Improve Implementation of the Risk Management Program for Airborne Chemical Releases (EPA OFFICE OF INSPECTOR GENERAL)
EPA can improve its program management and oversight to better assure that facilities covered by the Clean Air Act’s Risk Management Program submit or re-submit an RMP. EPA had not established national procedures for identifying covered facilities that had not submitted RMPs. For the 5 States reviewed, we identified 48 facilities in 3 States that reported large amounts of covered chemicals stored...
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Not enough water is a bad thing and too much water is a bad thing in Anhydrous Ammonia Processes
This article is for ANYONE with anhydrous ammonia, regardless if you have 100 pounds or 100,000 pounds of ammonia and your primary means of containment is Carbon Steel. I have written numerous times about the Stress Corrosion Cracking (SCC) failure mode and shared numerous accidents and alerts regarding this failure mode. In this article, I want to point out a little PSM/RMP requirement that often...
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MAJOR CHEMICAL DISASTERS IN INDIA
MAJOR CHEMICAL DISASTERS IN INDIA   Origin of accident Year Date Location Products involved Number of Deaths Injured Evacuated Explosion (warehouse) 1992 29.04 New Delhi Chemicals 43 20   Fire at a chemical store 1994 13.11 New Delhi Toxiccloud (chemicals)   500   Leakage 1984 03.12 Bhopal* Methyl isocyanate 2800 50,000 200,000 Leakage 1989 05.05 Britannia...
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Understanding OSHA's HAZWOPER standard for Emergency Response
OSHA’s standards for general industry and the construction industry on hazardous waste operations and emergency response (29 CFR 1910.120 or 29 CFR 1926.65) cover all employees involved in: Clean-up operations of hazardous substances at uncontrolled hazardous waste sites required by Federal, state, local or other governments; Corrective actions involving clean-up procedures at sites covered by the...
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Three Approaches to Safety Management (Reason, 1997)
Despite their differences in tradition, emphasis, and application domains, there is no reason why these various models and their associated practices should not coexist harmoniously within the same organization so long as the strengths and weaknesses of each approach are recognized. … HomeRead More »
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Protecting Powered Industrial Equipment Operating in and Around Explosion Hazardous Areas And Explosive Atmospheres
History has shown that flammable vapor ignitions in a number of cases have been proven to reside in mobile equipment working in or around a facility. “Industrial Loader and Forklift Fires,” an NFPA report published in January 2009, states that between 2003 and 2006, an average of 1,340 fires were ignited by heat or ignition sources found on powered industrial loaders and forklifts. … HomeRead...
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