PHMSA proposes revisions to the pipeline safety regulations to require operators of gas distribution pipelines to update their distribution integrity management programs (DIMP), emergency response plans, operations and maintenance manuals, and other safety practices These proposals implement provisions of the Leonel Rondon Pipeline Safety Act—part of the Protecting our Infrastructure of Pipelines...

I don’t think many safety pros would argue with this statement:  LOTO requires that all forms of hazardous energy be taken to a ZES before servicing and maintenance begin. But I have had many discussions about DEFINING and QUANTIFYING what a “hazardous form of energy” is.  Since OSHA has not quantified the term “hazardous energy”, many written LOTO programs and...

The United States Court of Appeals for The Sixth Circuit says it does.  More than fifty years ago, Congress passed, and President Nixon signed into law, the Occupational Safety and Health (OSH) Act, 29 U.S.C. § 651 et seq. Throughout the next half century, challenges to the constitutionality of the Act have been uniformly rejected. See Nat’l Mar. Safety Ass’n v. Occupational Safety & Health...

Earlier this month, I wrote Cuts so deep that workers can’t participate in their safety process concerning how reorganizational changes can lead to a lean workforce that the workers who need to participate in their safety process do not have the time to.   Now, let’s take a look at what happens when the layer of field supervision is cut so deep that we lose the ability to have...

This NASA Handbook defines the NASA Human Factors Analysis and Classifications System (NASAHFACS) tool and provides guidance on the use of NASAHFACS. It illustrates the NASAHFACS model; describes the data gathering, coding, trending, and tracking process and outlines training and other related resources to support the practice of NASAHFACS throughout NASA. CLICK HERE for the handbook

Never forget that management is intended to drive the “safety vehicle.” We are just the GPS navigation helping plot the course and stay on course.

Professor James Reason had a similar image to today’s “Work as imagined vs. Work as done” model. This image is from his 1997 book titled “Managing the Risks of Organizational Accidents“ It shows the “ideal” layers of protection model (i.e., the pieces of cheese with no holes) vs. the “reality” (i.e., the pieces of cheese with many holes) …...

One of the most common valves used in industrial settings is the 1/4-turn ball valve.  From 1/4″ up to 6″, these valves are everywhere, regardless of the risks they may pose.  Recently a client and I discussed these valves and their risk in highly hazardous chemical processing.  I have had several incidents over my career where this type of valve led to LOPC events, some...

The 100-Hour Rule is the theory that to master a topic and get the benefits of greatness doesn’t need to take 10,000 hours. Rather, it can often take approximately 100 hours if you break down skills into rare and valuable micro-skills. It is an exciting study that seems to have some validity to it.  Basically, if we spent just 18 minutes a day (100 hours a year), we could master a skill. Now industrial...

What is the difference between “root cause” and “direct cause”? (Please note that I am only using the single tense of these terms in the question; I am not implying these causes can only be singular.) But I tend to see a lot of “direct causes” being tagged as “root causes,” and in my eye, they can be and typically are vastly different. Example: a pleasure craft (boat) sank, killing both parties on...

“A major flaw in our system of government, and even in industry, is the latitude allowed to do less than is necessary. Too often, officials are willing to accept and adapt to situations they know to be wrong. The tendency is to down-play problems instead of actively trying to correct them. Recognizing this, many subordinates give up, contain their views within themselves, and wait for others...

Most of us who were adults in the 2000s can recall some silly claims made by “Infomercials.”  You know… “The Juicer,” the “no-stick pan,” the “Snuggie,” the knives that slice a beer can and tomatoes, the “Shamwow” towel, and the list go on and on.  Oh man, could they make the product seem as if you just had to have it, that...