I took this photo as part of an investigation to assist a potential new client in their defense against an OSHA citation.  This setup is exactly what OSHA took issue with.  A DOT container “dropped” and was being used as a “storage tank” since its motive power had been removed. This practice caused the PSM threshold for flammable liquids (e.g. 10,000 pounds) to be...

Here Heinrich speaks to the critical role employees play in THEIR safety process. This is where he speaks to keeping interest in safety high and how businesses should go about doing this. He points to employee participation as the critical piece of this effort. “Of course, keeping guards in place is but one of the many phases of industrial-accident prevention in which the work of creating and...

The folks “up north” are miles ahead of OSHA and EPA process safety standards in one simple but HUGE difference… Process Safety Leadership for Senior Management.  This standard, not fully embraced by all provinces within Canada, is something that OSHA and EPA should consider adopting in their efforts to revise their compliance standards.  This 2022 revision of CSA Z767:17...

CSA Z767 stipulates that human factors must be considered in risk identification and quantification.  In doing so, the design of operator process/equipment interfaces with written guidelines and procedures, staffing levels, and the working environment (noise, vibration, lighting, temperature) should all be considered from the perspective of their effect on both the levels of protection (line of...

After seeing all the complaints online about the referees in this weekend’s NCAA Women’s Championship game I was reminded of how too many safety pros take on the role of “referee” rather than a “coach” at their facility. It is a mistake made by many younger safety pros who do not have a mentor in their careers and trust me, the people who should OWN SAFETY are more than...

“This view of accident causation suggests that unsafe acts are best reduced by eliminating their psychological precursors rather than the acts themselves. However, it must be accepted that whatever measures are taken, some unsafe acts will still occur. It is therefore necessary to provide a variety of defenses to intervene between the act and its adverse consequences. Such defenses can be both...

The LinkedIn groups are at it again and again I will defend their latest outrage.  This time it is “safety metrics”.  So let’s recap; so far they have attacked the safety management system, root cause analysis, and risk matrices, and now we move to safety metrics.  And like the times before, their rhetoric is way over the top, using terms like “evil” and...

Respondent owns and operates a petroleum product refinery. In May 2017 there was a refinery-wide power outage that resulted in flaring and a large release of sulfur dioxide and flammable materials from the Facility. In response to this incident, members of the public were evacuated, required to shelter in place, or visited the emergency room of local hospitals. In March 2019, the Facility experienced...

There are three (3) recognized models upon which Safety Management Systems are built.  These models were identified via Dr. James Reason’s research and still hold true today, 30 years later.  Safety professionals have to be sure as to not allow their biases to influence which one is best for the organization, as all three have significant differences and can have dramatic impacts on...

As I have said many times, we MUST examine all Latent Organizational Failures before we even begin to look at the actions of the worker(s).  Far too often, investigations will first (and usually only) look at the ACTIVE failures that led to the consequences.  This is how so many accidents IMPROPERLY and UNFAIRLY get put on the back of the worker(s) involved.  Even when those actions...

A highly resilient organization is a LEARNING organization. Learning organizations exhibit five (5) main characteristics: system thinking, personal mastery, mental models, a shared vision, and team learning … HomeRead More »

Highly reliable organizations use a portfolio of programs to maintain the continual improvement of system designs, procedures, and policies. This continuous improvement process allows the organization to RECOGNIZE OPERATIONAL AND ENVIRONMENTAL VARIATION EARLY and TO DEVELOP CORRECTIVE ACTIONS TO BRING THE SYSTEM BACK TO STABILITY The goal of this continuous improvement process is to: PREVENT errors,...