“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 [...]
“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 [...]
“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, [...]
“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 [...]
“ ‘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. [...]
“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 [...]
“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 [...]
“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 [...]
“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 [...]
“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 [...]
