What If There Was No PSM Standard?

“What’s the use you learning to do right when it’s troublesome to do right and ain’t no trouble to do wrong, and the wages is just the same?”  — Mark Twain, in The Adventures of Huckleberry Finn We love to hate regulations. The harder it is to comply with them, the more we hate them. [...]

By |2020-03-26T14:35:52+00:00March 26th, 2020|Process Safety, Process Safety Management|0 Comments

Process Safety: How Far We’ve Come

“Life is a journey and not a destination.”  — Lynn H. Hough When Richard Nixon signed OSHA into law in 1970, the United States was looking at 14,000 work-related fatalities per year. With a workforce of about 70 million full-time equivalents, the work-related fatality rate was about 20 fatalities per 200,000,000 hours worked. In 2018, [...]

Villains, Victims, and Heroes in Process Safety

“You’re a hero one day, you’re a villain another day.”  — Vincent Tan Every good story is a story of conflict. It has a villain. It has a victim. And in the best stories, it has a hero. The story of a process incident or scenario is no different. It has villains—causes. It has victims—receptors, [...]

3 Criteria for Picking LOPA Scenarios

“The easiest way to solve a problem is to pick an easy one.”  — Franklin P. Jones We love having choices. We hate making choices. What if we pick wrong? There is no shortage of people ready to tell us. It is always helpful to have criteria for choosing, or to be honest, to justify [...]

Breaking Up Is Hard to Do: HazOp Nodes

“Come on, baby, let’s start anew, ‘cause breaking up is hard to do.”  — Neil Sedaka Before a HazOp team ever assembles, the facilitator has some important tasks to complete: get agreement with management on the scope of the review, identify the boundaries of the study, and break the process up into nodes.  And breaking [...]

By |2020-01-09T16:34:36+00:00January 9th, 2020|PHA, Procedures, Process Safety Management|1 Comment

Everyone Gets a Prize: Employee Participation

“Nor should participation trophies be offered for simply showing up.”  — Kevin Dickenson OSHA is fond of pointing out that the Process Safety Management Standard, 29 CFR-1910.119 (PSM), is a performance-based standard.  While they generally avoid telling us how to comply with standard, they expect us to comply with standard, nonetheless.  There is no prize [...]

By |2019-12-12T15:11:38+00:00December 12th, 2019|Procedures, Process Safety Management|1 Comment

Improving Human Performance Reliability

 “We must accept human error as inevitable - and design around that fact.”  — Donald Berwick The idea of human error and its contribution to industrial incidents has been the center of debate in recent years.  If you’ve been part of more than one incident investigation, you’ve probably experienced an incident being attributed to human [...]

Out of the Blocks: Credit for Human Response

“Fear is often our immediate response to uncertainty.”  — Gabrielle Bernstein In 2001, when the CCPS book, Layer of Protection Analysis: Simplified Process Risk Assessment, “the purple book”, stated that human response is “a relatively weak protection layer” and “less reliable than engineering controls”, many people were willing to accept that piece of conventional wisdom. [...]

We’re Not Wizards

“But how they can be charged with negligence because they were not wizards, appellant’s brief does not make clear.”  — Osmond K. Fraenkel, successfully arguing before the New York Supreme Court, 1935 In a world where companies tout “Zero Incidents,” not as an aspirational definition of perfect safety, but as a measurable and achievable target, [...]

PSM Auditor: Coach or Umpire?

“Umpires don’t make the rules.  They apply them…They make sure everybody plays by the rules.  But it is a limited role.  Nobody ever went to a ballgame to see the umpire.”  — Supreme Court Chief Justice John Roberts A call about doing a PSM audit usually begins with a question from the caller about whether [...]