Risk Management Plans: How Many?

“I have so much paperwork. I’m afraid my paperwork has paperwork.”  — Gabrielle Zevin One of the key differences between OSHA’s Process Safety Management (PSM) standard and the EPA’s Risk Management Planning (RMP) rule is the RMP rule’s requirement to submit documentation to the EPA. OSHA has no similar requirement for submission. If OSHA wants [...]

By |2026-01-08T12:37:41-06:00January 8th, 2026|Chemicals, Procedures, Process Safety|Comments Off on Risk Management Plans: How Many?

“OSHA Says”: Making a List, Checking It Twice

“You know what’s the greatest part of anything ever in the history of everything? Exaggeration. No wait; it’s correcting yourself. No, better yet, it’s making lists.” — Demetri Martin When Google offers an AI response, it includes a statement: “AI responses may include mistakes.” That was never so obvious to me as when I posed [...]

By |2026-01-14T18:26:57-06:00December 18th, 2025|Craft Distillery Safety, Procedures, Process Safety, Process Safety Management, Workplace Safety|Comments Off on “OSHA Says”: Making a List, Checking It Twice

Hot Potato

“More often than not, to blame someone else is to play ‘hot potato’ with something that’s neither hot nor a potato.”  — Craig D. Lounsbrough Imagine you work at a plant that makes a polymer. One of the raw materials is the monomer and it is toxic, reactive, and flammable. It contains an inhibitor to [...]

By |2025-09-18T09:55:07-05:00September 18th, 2025|Procedures, Process Safety, Workplace Safety|Comments Off on Hot Potato

Confined Spaces: Even in Craft Distilleries and Microbreweries

“I have a horror of being in confined spaces.”  — Hayley Mills At a craft distillery that is not too far from Bluefield’s offices, the owner spoke about his need to climb into the pot still to clean out the stillage, especially the spent grains. He saw me wince and said, “Yeah, I know. It’s [...]

By |2025-11-06T11:12:04-06:00September 11th, 2025|Craft Distillery Safety, Procedures, Process Safety, Workplace Safety|Comments Off on Confined Spaces: Even in Craft Distilleries and Microbreweries

Recordkeeping for Process Safety: Permit Retention

“A memorandum is not to inform the reader but to protect the writer.”  — Dean Acheson A reader asked me “How long do I need to keep confined space entry permits for a covered process?” He knew my thoughts on retaining hot work permits and wondered if the same approach applied to other permits in [...]

By |2025-07-10T09:32:30-05:00July 10th, 2025|Procedures, Process Safety, Process Safety Management|Comments Off on Recordkeeping for Process Safety: Permit Retention

Incidents: Under Reporting

“Complaints are prayers to the wrong god.”  — Anne Lamott We live in a culture that actively discourages reporting problems. We’re told “Complain less, appreciate more,” “No one likes to listen to complaints,” and “Never complain and never explain.” And extreme cases, we’re reminded that “Snitches get stitches.” Yet there are dozens of requirements to [...]

By |2025-06-26T16:21:29-05:00June 26th, 2025|Procedures, Process Safety, Process Safety Management, Workplace Safety|Comments Off on Incidents: Under Reporting

Run To Failure: That’s a Maintenance Strategy?

“What’s wrong with the car? What do you think’s wrong with the car? Damn thing’s broke.”  — Richard Pryor When I was a poor college student, I wasn’t too poor to have an old beater of a car. It was paid for, but I could barely afford gas, much less proper maintenance. So, I tended [...]

By |2025-06-12T13:21:45-05:00June 12th, 2025|Procedures, Process Safety, Workplace Safety|Comments Off on Run To Failure: That’s a Maintenance Strategy?

Hazard Communication: Does Whiskey Need an SDS?

“Whisky making is an act of cooperation between the blessings of nature and the wisdom of man.”  — Masataka Taketsura While on a tour of a craft distillery, the distiller (and owner) and I got to talking about the safety aspects of distilling whiskey. The question of whether whiskey needed an SDS came up. It [...]

By |2025-11-06T11:15:52-06:00May 15th, 2025|Chemicals, Craft Distillery Safety, Procedures, Process Safety|Comments Off on Hazard Communication: Does Whiskey Need an SDS?

Beyond the Limits: Extreme Oxygen

“Oxygen is the vital ingredient for the survival of every cell in our bodies. Too little—or too much—can spell disaster.”  — Venki Ramakrishnan A reader recently complained about OSHA’s insistence on defining the safe limits of oxygen in terms of volume percent: 19.5% by volume to 23.5% by volume. “The fact that OSHA does not [...]

By |2025-05-01T09:33:23-05:00May 1st, 2025|Procedures, Workplace Safety|Comments Off on Beyond the Limits: Extreme Oxygen

Process Hazards: Using Compressed Gas to Transfer Liquids

“Science explorers are like an ideal gas. They can expand to fill any volume, but they can only do work under pressure…and the pressure’s on.”  — Robert Ballard Every time that someone at a process facility tells me that they use compressed gas to transfer liquids from one tank to another, I wince. It’s not [...]

By |2025-04-17T10:00:59-05:00April 17th, 2025|Chemicals, Gas, Procedures, Process Safety, Workplace Safety|Comments Off on Process Hazards: Using Compressed Gas to Transfer Liquids
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