A piece of safety to ponder over your weekend… Auditing is NEVER about the number of findings. We just experienced a facility with no PSM/RMP elements in place, and they have three (3) covered processes. With nothing to audit, they ended up with less than 25 findings (but they are massive findings that will take years to close). A sister facility we audited in January with an advanced PSM/RMP...

Control banding is a generic technique used to guide the assessment and management of workplace risks for chemicals without an occupational exposure limit (OEL). The majority of chemicals in commercial use do not have an established OEL. OELs include NIOSH Recommended Exposure Limits (RELs) and OSHA Permissible Exposure Limits (PELs). OELs help to assess and manage chemical risks in the workplace....

WHY OIG CONDUCTED THE AUDIT OSHA is responsible for ensuring safe and healthful working conditions for millions of workers nationwide and does so partly by conducting inquiries and inspections of potential hazards. For Fiscal Year (FY) 2019 and FY 2020, inspections from complaints and referrals were slightly greater than 40 percent of OSHA’s total inspections. A complainant expressed concern that OSHA...

I have written extensively about James Reason’s Human Failure model and how it applies to almost all workplaces.  Today I want to discuss specifics on how to use his model in our causal analysis.  For those already using some form of a Fault-Tree Analysis, such as TapRoot, you already have this capability built into your software.  But many are not using commercial software to...

Inside storage rooms (Liquid Storage Rooms) are normally used: when the containers are opened for mixing, pouring, dispensing, or transfer of flammable liquids; if the quantity is too large to fit into an approved cabinet; if the quantity is excessive for any one fire area; and/or if the opened containers cannot be separated from potential sources of ignition. As defined by NFPA 30 paragraph...

Recently we worked with an organization that was struggling to control its risks around the use of ATVs and UTVs.  After several serious accidents involving these machines, we were asked to review their “Barriers,” “Controls,” and “Safeguards” in place to control the risks associated with these machines.  We found a program and training on the said program...

The Department of Industrial Relations Occupational Safety and Health Appeals Board (OSHAB) has issued a precedential decision regarding the provision of water at outdoor worksites, affirming that it must be as close as practicable to the areas where employees are working to encourage frequent consumption. The case clarified the definition of what “as close as practicable” means with water placement...

During well operations, a fatality occurred on a drillship in the Gulf of Mexico.  While unlatching the lower Marine Riser Package from the Blowout Preventer in preparation for ship relocation, a crew member was lifted into the air after being struck by a hydraulic torque wrench (HTW), hitting a riser clamp approximately six feet above the elevated work deck before falling to the rig floor. The...

Think about the kids who came from abusive homes vs. those who came from supportive homes where they knew they were loved. It isn’t all peaches and cream, but they KNOW when they are loved and supported, and it shows in how they live their lives and in how they make decisions. We hold our kids responsible when they fail but look at the number of posts on social media of parents celebrating their...

Over my career, the most profound advancement in safety management was the recognition and shift away from lagging indicators (i.e., injury rates) to leading indicators within our safety management system (SMS).  But as this approach to safety metrics became more widespread, we have seen even leading indicators become a “number game” that gets manipulated as much as the old “OSHA...

If you think safety metrics is old fashion and leads to “manipulating behaviors”, go out to your car and disconnect your dashboard/pull fuses so that you get no analytical feedback data on how well you are staying within your safe operating envelope of yours and the car’s performance. Then tell me metrics are not needed in safety management. If you’re not a believer in leading indicators let’s...

If the phrase “safety culture” has become so toxic in today’s world, is it wrong to use the phrase “culture of safety”? I mean, it is nonsense to claim an organization has no culture. Some can say it over and over, but that does not mean it is right. ALL groups have a culture that shapes their decision-making. So having a “culture of safety” simply implies...