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. [...]

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

Incident Investigations: When Are They Needed?

“It seems to me that at this time we need education in the obvious more than investigation of the obscure.”  — Oliver Wendell Holmes, Jr. OSHA requires incident reports. For recordable injuries or illnesses, OSHA requires that a 301 Form, Injury and Illness Incident Report, be completed, per 29 CFR 1904.29(a). For workplaces with PSM-covered [...]

By |2026-02-06T14:52:33-06:00February 6th, 2026|Procedures, Process Safety, Process Safety Management, Workplace Safety|Comments Off on Incident Investigations: When Are They Needed?

Process Safety: When “Normal” Isn’t Normal

“You keep using that word. I do not think it means what you think it means.” — Mandy Patinkin as Inigo Montoya from The Princess Bride (1987) I, like many older Americans, worry about my blood pressure enough to check it regularly. And like most people who check their blood pressure regularly, I know what [...]

By |2026-01-29T11:00:03-06:00January 29th, 2026|Procedures, Process Safety, Process Safety Management|Comments Off on Process Safety: When “Normal” Isn’t Normal

Pressure Relief in Distilleries

“Pressure’s what you make of it.”  — Daniel Ricciardo Years ago, a colleague told me, “If the pressure is too high, it’s going to find a way to relieve. If you don’t plan for pressure relief, then you don’t get to pick how and where it relieves. And that can be disastrous.” For every piece [...]

By |2026-01-16T14:24:13-06:00January 16th, 2026|Craft Distillery Safety, Process Safety, Process Safety Management|Comments Off on Pressure Relief in Distilleries

“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

Combustible Dust: Probability of Ignition

“Before the first atomic bomb test, scientists took the time to calculate whether the blast would ignite the nitrogen in the Earth’s atmosphere and incinerate us all. The risk was low and the test went off, but Rees wonders what the odds would have had to be to discourage the bomb makers.”  — Dennis Overbye [...]

By |2025-10-30T10:55:47-05:00October 30th, 2025|Process Safety, Process Safety Management, Workplace Safety|Comments Off on Combustible Dust: Probability of Ignition
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