Based on eight (8) recent enforcement investigations, conducted by the U.S. Department of Transportation, Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Hazardous Materials Enforcement (OHME), this letter is intended to notify the industry of serious safety problems and non-compliance issues regarding the maintenance, filling, transport and use of nurse tanks in anhydrous...

Human factors are concerned with optimizing human performance in all tasks and in major hazard workplaces; the primary intention is to achieve safe performance. These high-risk workplaces should have conducted risk assessments and established a range of controls to prevent major accidents. Still, they should also focus on human performance issues to eliminate or reduce human failures. An organization’s...

Twelve days before the Holidays,  My Safety Team said to me,     No cuts or lacerations  Wear your PPE,     No slips, trips or falls  Watch where you put your feet,    No strains, aches or pains  Use your safe lifting techniques,     Watch your head and keep it safe  Always be aware of overhead space,     Wear glasses, wear gloves  And...

Organizational weaknesses are vulnerabilities, flaws, and defects in controls (engineered, administrative, cultural, and oversight controls). Searching for and eliminating latent organizational weaknesses eliminates factors contributing to significant events. … HomeRead More »

This article discusses how a facility would need to get one of its coded pressure vessels repaired, altered, or re-rated. The article will cover pertinent code and jurisdiction requirements and the differences among the American Society of Mechanical Engineers (ASME) Code, the National Board Inspection Code (NBC), and American Petroleum Institute (API) requirements, as well as discuss the following:...

A Process Hazard(s) Analysis is a thorough, orderly, and systematic approach for identifying, evaluating, and controlling the hazards of processes involving highly hazardous chemicals. The facility shall perform a process hazard analysis on all processes covered by EPA’s RMP rule and/or OSHA’s PSM standard. The process hazard analysis methodology selected must be appropriate to the complexity...

HAZWOPER EMERGENCY RESPONSE PLAN DEVELOPMENT GUIDELINES(Elements of an Emergency Response Plan)1910.120(q)(2)  (i)  Pre-emergency Planning and Coordination with outside parties Facilities are required in the Superfund Amendments and Reauthorization Act (SARA) title III to coordinate their activities with outside response organizations and emergency response organizations. The emergency response...

Are there any recordkeeping requirements specified in the risk management program (RMP) regulations in 40 CFR Part 68? The owner or operator of a stationary source that is subject to the RMP regulations must maintain records supporting the implementation of Part 68 for five years (§68.200).

Error Management (EM) has two (2) components: error reduction and error containment Error reduction comprises measures designed to limit the occurrence of errors. Since this will never be wholly successful, we also need error containment measures designed to limit the adverse consequences of those errors that still occur. At this general level, EM is indistinguishable from quality management or,...

Fostering the principles for a strong safety culture is one of the most challenging tasks facing a management team. Successful leadership achieving a strong safety culture will most likely move an organization to the next level of human performance. A leader is any individual who takes personal responsibility for his or her performance as well as the facility’s performance and attempts to influence...

I have used this tool, with some modern-day modifications, for years.  When I was a safety manager of a facility I would constantly be looking for these indicators as a means to validate what I was “feeling”.  As safety pros, we have a sixth sense of how things are going, but there are so many markers/indicators in measuring safety cultures that having a list like this comes in...

“Name, blame, shame, retrain” is an often-used phrase for older ineffective paradigms of safety management and accident analysis. Dr. Rosabeth Moss Kanter of Harvard Business School phased the situation this way: “Accountability is a favorite word to invoke when the lack of it has become so apparent.” Kanter, 2009 The concepts of accountability, culpability and just culture are inextricably entwined....