Tick Tock, Tick Tock: Is It Time for a PHA Revalidation?

“Time keeps on slipping, slipping, slipping, into the future.”  — Steve Miller The Process Safety Management (PSM) standard, 29 CFR 1910.119, states in (e)(6) that “At least every five (5) years after the completion of the initial process hazard analysis, the process hazard analysis shall be updated and revalidated by a team meeting the requirements [...]

By |2025-01-23T10:56:23-06:00January 23rd, 2025|PHA, Process Safety, Process Safety Management|0 Comments

Recommendations: Evolution of an Approach

“The hardest thing is writing a recommendation for someone we know.”  — Kin Hubbard We’ve all heard, over and over, that data without analysis is useless. Well, analysis without recommendations is just as useless. Unfortunately, many young engineers are incredible analysts but then mistakenly believe that their analysis will stand on its own, that the [...]

By |2025-01-09T10:31:25-06:00January 9th, 2025|PHA, Process Safety, Process Safety Management|Comments Off on Recommendations: Evolution of an Approach

Risk Management: Are Hurricanes Really Getting More Frequent?

“The head of the hurricane research division, Hugh Willoughby, told me that hurricanologists can predict the behavior of storms if those storms behave predictably.”  — Erik Larson Hurricane season is officially from June 1 to November 30, so it’s not officially over yet. A look at the Atlantic, however, shows no tropical depressions developing and [...]

By |2024-11-22T13:05:43-06:00November 22nd, 2024|Current Events, PHA, Process Safety Management, Risk Assessment|Comments Off on Risk Management: Are Hurricanes Really Getting More Frequent?

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 |2025-01-14T13:52:03-06:00October 18th, 2024|Chemicals, Current Events, PHA, Safety Lifecycle|Comments Off on STAA: Just a Little Bit Longer

Unusual Process Hazards: Manhole Covers

“If I had a nickel for every time this happened, I’d have two nickels. Which isn’t a lot, but it’s weird that it happened twice. Right?”  — Dr. Heinz Doofenshmirz Friends and acquaintances recently flooded my inbox with stories about a series of sewer explosions near the north riverfront of St. Louis. It launched several [...]

By |2025-01-14T13:58:57-06:00September 5th, 2024|Chemicals, Current Events, Process Safety|1 Comment

…And Their Representatives

“Representation not only reflects, but actually changes reality.”  — Angela Chen OSHA has several regulations that allow or require employee participation in activities regarding workplace safety. For instance, there is employee participation during OSHA inspections and in the development of the elements of the Process Safety Management (PSM) standard. And those regulations don’t stop at [...]

By |2025-01-16T13:00:34-06:00August 31st, 2023|PHA, Process Safety Management|2 Comments

Too Many Players on the Field: PHA Teams

“Meetings should have as few people as possible, but all the right people.”  — Charles W. Scharf Ever been in a Process Hazard Analysis (PHA) meeting where there were over a dozen people? Wasn’t it excruciating? Either you wondered why you needed to be there, or you wondered why some of the other people needed [...]

By |2025-01-16T13:09:59-06:00August 24th, 2023|PHA, Process Safety Management|Comments Off on Too Many Players on the Field: PHA Teams

Consider: A Weasel Word?

“For having lived long, I have experienced many instances of being obliged, by better information or fuller consideration, to change opinions, even on important subjects, which I once thought right but found to be otherwise.” — Benjamin Franklin The first time you ever encountered a weasel word was probably when your mom said, “Maybe,” or [...]

By |2022-06-02T13:30:01-05:00June 2nd, 2022|Chemicals, PHA, Process Safety Management, Recommendations|Comments Off on Consider: A Weasel Word?

Process Risk: Learning from Experience

“We do not learn from experience…we learn from reflecting on experience.”  — John Dewey There are too many celebrities and philosophers to count who have talked about the importance of their mistakes in shaping them. Many seem quite pleased, even proud, of the mistakes they’ve made and their ability to rise from them and go [...]

By |2025-01-16T14:43:37-06:00February 24th, 2022|PHA, Process Safety, Workplace Safety|Comments Off on Process Risk: Learning from Experience

KISS: Keep It Simple = Safety

“Simplicity is prerequisite for reliability.”  — Edsger Dijkstra For most of my life, I have struggled to keep down to a healthy weight. It didn’t help when someone told me, “Losing weight is simple. Eat less.” When I protested, they replied, “I said it was simple. I didn’t say it was easy.” The safest plant [...]

By |2025-01-16T14:44:13-06:00February 3rd, 2022|PHA, Process Safety|Comments Off on KISS: Keep It Simple = Safety
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