PSM

If we are not trending the findings from our 3-year PSM/RMP audits, WTH are we doing?

We see this far too often… a management system failure related to 3-year PSM/RMP audits. A company with multiple facilities should be “trending” its 3-year audit findings to IDENTIFY opportunities for improvement across the company. I did this years ago when I was a member of the Corporate EHS Team for a semi-conductor. And was

CSB Issues Final Report into 2023 Fire at a Renewables Facility in Martinez, CA

Fire Severely Burned an Employee and Resulted in $350 Million in Damages The CSB released its final investigation report into the November 19, 2023, fire at the renewable diesel facility in Martinez, CA.  The incident seriously injured one employee, who suffered third-degree burns over most of his face and body and resulted in approximately $350 million in

Never be too confident of our written SOPs/JSAs

We MUST never be too confident of our written SOPs/JSAs. There is a good reason why “Administrative Controls” are down on the Hierarchy of Controls. When we think our SOPs/Plans are infallible, our workers will show us a thing or two… And when we investigate adverse events and this leads us to “failure to follow

An MOC for relocating a production line in a food processing facility?

Victor Dearman Jr. CIRO, CRST No, it doesn’t involve anything with refrigeration. Same equipment, the same people, and a better layout to improve efficiency. So why would an MOC be required if it doesn’t impact refrigeration/PSM? Well, we have to think a little beyond equipment changes in the refrigeration system for a moment, or procedural

When will the ammonia refrigeration industry finally embrace LOTO? (Part II)

Victor Dearman Jr. CIRO, CRST One of the challenges to my post was “What if the flagging tape was to indicate that the valve was in an abnormal position?” This was followed up with a challenge as to whether or not anything forbids such a method. Operating procedures should be designed to meet the requirements

One of the questions I got after the CSB Update on the PV failure in KY was…

“Why did they have a Rupture Disc and a Relief Valve together?” As I alluded to in my post regarding CBS’s update, this arrangement is fairly common but comes with some very SPECIFIC requirements. These requirements can be found in: But the top four (4) requirements, we as safety engineers should be looking for in

RESPECT the Cl2

At approximately 9:45 p.m. on November 4, 2003, a maintenance employee went to the chlorine house to turn on the chlorination system. The chlorine house measured 3 feet, 10-inches wide by 5 feet, 10-inches long and was approximately 10-feet high. The water lines ran through a hole in the block wall. The hole in the

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