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|0 Comments

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 |2024-09-05T13:59:57-05:00September 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 |2023-08-31T15:37:00-05:00August 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 |2023-08-24T15:09:17-05:00August 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 |2022-02-24T14:56:55-06:00February 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 |2022-02-03T16:03:10-06:00February 3rd, 2022|PHA, Process Safety|Comments Off on KISS: Keep It Simple = Safety

Speed Of Thought

The degree of slowness is directionally proportional to the intensity of memory. The degree of speed is directionally proportional to the intensity of forgetting.” ― Milan Kundera, Slowness Every industry uses speed as a measurement to quantify productivity.  That productivity, whether gallons or railcar loads, is a tangible result that translates into revenue for a company.  Speed [...]

By |2021-10-07T14:55:38-05:00October 7th, 2021|PHA, Process Safety, Workplace Safety|Comments Off on Speed Of Thought

Batch Processes: Consider a Procedural HazOp

“We know we need civilization and laws and procedures, but isn’t it frustrating? Wouldn’t it be great if we could just do what we needed to do?”  — Lee Child When someone thinks about a Process Hazard Analysis, a PHA, they usually think about a Hazard and Operability Review, a HazOp. And when they think [...]

By |2021-09-30T17:01:53-05:00September 30th, 2021|Chemicals, PHA, Procedures, Process Safety, Process Safety Management|Comments Off on Batch Processes: Consider a Procedural HazOp

Operator Errors: Are They Really Design Errors?

“To err is human, to forgive, divine.”  — Alexander Pope I was in a PHA once where the lone operator on the PHA team finally grew weary of the discussion of operator error.  “Why is it that when you engineers make a mistake, you call it design error, but when I make a mistake, you [...]

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