STAA: Just a Little Bit Longer

“Because things are the way they are, things will not stay the way they are.”  — Bertolt Brecht Of all the recent revisions to the EPA’s Risk Management Planning (RMP) rule, 40 CFR 68, the requirements around Safer Technology and Alternatives Analysis (STAA) have probably gotten the most attention. For those facilities covered by Program [...]

By |2024-10-18T09:14:26-05:00October 18th, 2024|Chemicals, Current Events, PHA, Safety Lifecycle|Comments Off on STAA: Just a Little Bit Longer

The Shipping News

“Eighty thousand pounds of muscle, blood, and steel in a pile. It’s spectacular.”  — Gary Williams No plant in the chemical process industries wants to make the national news. The local news, where the plant’s scholarships for high school students is covered? Sure. But the national news? The only things that get national coverage are [...]

By |2024-02-02T14:43:39-06:00August 25th, 2022|Chemicals, Procedures, Process Safety, Safety Lifecycle|Comments Off on The Shipping News

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 [...]

By |2020-01-16T14:45:24-06:00January 16th, 2020|PHA, Process Safety Management, Risk Assessment, Safety Lifecycle|Comments Off on 3 Criteria for Picking LOPA Scenarios

Inconceivable: Unrecognized Hazards

“You keep using that word.  I do not think it means what you think it means.”  - Mandy Patinkin as Inigo Montoya, in The Princess Bride I find the phrase “While we never anticipate a loss of cabin pressure…” incredibly annoying.  To anticipate means to think of something that will or might happen in the [...]

By |2019-12-05T14:08:07-06:00December 5th, 2019|Process Safety, Risk Assessment, Safety Lifecycle|1 Comment

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, [...]

By |2019-10-17T18:14:52-05:00October 17th, 2019|PHA, Process Safety Management, Risk Assessment, Safety Lifecycle|Comments Off on We’re Not Wizards

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 [...]

By |2019-09-19T14:40:23-05:00September 19th, 2019|Process Safety, Process Safety Management, Recommendations, Safety Lifecycle|Comments Off on PSM Auditor: Coach or Umpire?

Lab Safety: A Three Phase System

“A pint of sweat will save a gallon of blood.”  George S. Patton, Jr. I intended to begin with “A good plan, well executed, is better than a perfect plan, poorly executed,” but when I checked, that’s not what General Patton said.  What he said was “A good plan, violently executed now, is better than [...]

By |2019-05-09T14:05:13-05:00May 9th, 2019|Chemicals, PHA, Procedures, Process Safety, Risk Assessment, Safety Lifecycle|Comments Off on Lab Safety: A Three Phase System

Wait For It! Are Trip Delays Okay?

“But the important thing about learning to wait, I feel sure, is to know what you are waiting for.”  —Anna Neagle Many safety instrumented functions (SIFs) are deliberately designed to wait before tripping.  Like a sergeant commanding his troops to “Wait for it!” the SIF designer is anxious that the SIF not trip prematurely. Some [...]

By |2018-03-08T15:01:42-06:00March 8th, 2018|Process Safety, Process Safety Management, Risk Assessment, Safety Lifecycle|Comments Off on Wait For It! Are Trip Delays Okay?

Safety Lifecycle – Part 3: Developing Risk Tolerance Criteria

“If we accept there is no such thing as ‘zero risk’ then we should not spin the meaning of words with assertions such as ‘all accidents are preventable.’ – Dr. Rob Long In terms of process safety, one definition of risk is, “[The] combination of the frequency of occurrence of harm [the likelihood] and severity [...]

By |2017-11-14T21:26:31-06:00October 12th, 2017|PHA, Process Safety, Process Safety Management, Risk Assessment, Safety Lifecycle, Workplace Safety|Comments Off on Safety Lifecycle – Part 3: Developing Risk Tolerance Criteria

Check Valves and Risk Assessment: Should You Take Credit?

“Unless you go forward then you are going back.”  - Greg Lake Check valves (CVs) are routinely installed as safeguards against reverse flow.  Just as routinely, check valves are dismissed as safeguards during process hazard analysis.  If check valves are of no value, then there is no point in installing them.  On the other hand, [...]

By |2017-11-14T21:24:36-06:00September 28th, 2017|PHA, Process Safety, Risk Assessment, Safety Lifecycle|8 Comments
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