The Elements of PSM: Trade Secrets

“This hour I tell things in confidence. I might not tell everybody, but I will tell you.”  — Walt Whitman I once worked at a plant that produced performance chemicals. Performance chemicals are sold based on what they do rather than what they are. The key specifications are the performance specifications, not the composition specifications. [...]

By |2026-09-03T14:54:33-05:00September 3rd, 2026|Chemicals, Process Safety, Process Safety Management|0 Comments

PHAs-The Difference Between HazOp and FMEA

“Apples and oranges aren’t that different really. I mean they’re both fruit. … I could understand if you said, ‘That’s like comparing apples with hermaphroditic ground sloths.”  — Chuck Klosterman A client recently asked us to “outline the difference in method and objective for FMEA vs. PHA/HAZOP and LOPA.” They were interested in evaluating system [...]

By |2026-08-14T13:54:06-05:00August 14th, 2026|PHA, Process Safety Management, Risk Assessment|Comments Off on PHAs-The Difference Between HazOp and FMEA

Management of Change: When Is It Regulated?

“If you want to truly understand something, try to change it.”  — Kurt Lewin All change should be managed; in any endeavor, under any circumstances. When people ask about management of change, however, they are usually talking about the specific regulatory requirements of the Occupational Safety and Health Administration (OSHA) and its Process Safety Management [...]

By |2026-08-06T10:47:15-05:00August 6th, 2026|Process Safety, Process Safety Management|Comments Off on Management of Change: When Is It Regulated?

Secrecy vs. Safety

“Bureaucracy and compliance now seem less about managing the safety of the workers we are responsible for, and more about managing the liability of the people they work for.”  — Sidney Dekker One of the foundations of process safety is that we learn from experience. Because relevant experience comes from making mistakes and facing failures, [...]

By |2026-07-30T12:07:11-05:00July 30th, 2026|Process Safety, Process Safety Management, Workplace Safety|Comments Off on Secrecy vs. Safety

Process Safety: Info We Need from Equipment Manufacturers

“If you don’t live up to somebody’s standards, you get hammered.”  — Anthony Rendon I drive a 2006 Toyota Corolla. When I bought it in 2008, the odometer read 11,499 miles. In 2013, when the odometer crossed the 100,000-mile threshold, I declared my hope to reach 250,000 miles. The car is now closing in on [...]

By |2026-06-25T14:50:58-05:00June 25th, 2026|Procedures, Process Safety, Process Safety Management|Comments Off on Process Safety: Info We Need from Equipment Manufacturers

Highly Volatile: Does That Mean Hazardous?

“ ‘When I use a word,’ Humpty Dumpty said in a rather scornful tone, ‘it means just what I choose it to mean neither more or less.’ ”  — Lewis Carroll, in Through the Looking-Glass When Administrative Law Judge Richard DeBenedetto ruled against OSHA in the case of Secretary of Labor v. Meer Corporation (No. [...]

By |2026-06-11T15:02:50-05:00June 11th, 2026|Chemicals, Process Safety, Process Safety Management|Comments Off on Highly Volatile: Does That Mean Hazardous?

Incident Investigations: Not a Trial by Jury

“When you go into court you are putting your fate into the hands of twelve people who weren’t smart enough to get out of jury duty.”  — Norm Crosby During the 15 years I have lived in the city of Saint Louis, I’ve been called for jury duty four times. The most recent was just [...]

By |2026-05-22T08:07:37-05:00May 22nd, 2026|Process Safety, Process Safety Management|Comments Off on Incident Investigations: Not a Trial by Jury

Regulating Chemical Safety: A Comparison of the EPA and OSHA

“The only thing that saves us from bureaucracy is its inefficiency. An efficient bureaucracy is the greatest threat to liberty.”  — Eugene McCarthy A client recently posed this question: “Why do you think the EPA is more willing to update its regulations than OSHA?” Is it? We gave a glib answer – resources – but [...]

By |2026-04-09T14:47:31-05:00April 9th, 2026|Process Safety Management, Workplace Safety|Comments Off on Regulating Chemical Safety: A Comparison of the EPA and OSHA

BLS Fatality Data: What Do Differences in the CPI Tell Us?

“One can state, without exaggeration, that the observation of and the search for similarities and differences are the basis of all human knowledge.”  — Alfred Nobel Yearly, the Bureau of Labor Statistics publishes fatality data for the U.S. workplace, private and public.  Usually, it is in December for the previous year. Because of the government [...]

By |2026-03-05T20:02:25-06:00March 5th, 2026|Process Safety Management, Workplace Safety|Comments Off on BLS Fatality Data: What Do Differences in the CPI Tell Us?

Chemical Incidents: Top Three Reasons

“Always lists to be made, as if writing items in neat vertical rows might stave off randomness and chaos.” — Dani Shapiro People love lists. Top Ten Lists. Top Twelve Lists. Casey Kasem’s American Top Forty. And for those with short attention spans, Top Three Lists. I recently received an email asking if I agreed [...]

By |2026-02-19T10:57:40-06:00February 19th, 2026|Chemicals, Process Safety, Process Safety Management, Workplace Safety|Comments Off on Chemical Incidents: Top Three Reasons
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