A+: What Is A Perfect PHA?

“Perfection is not attainable, but if we chase perfection, we can catch excellence.”  — Vince Lombardi I don’t believe that I have ever facilitated a perfect PHA. The question is, how would I recognize it if it was perfect? And would others agree? What exactly is a perfect PHA? A PHA Identifies Hazards The primary [...]

Beyond the Limits: Extreme Oxygen

“Oxygen is the vital ingredient for the survival of every cell in our bodies. Too little—or too much—can spell disaster.”  — Venki Ramakrishnan A reader recently complained about OSHA’s insistence on defining the safe limits of oxygen in terms of volume percent: 19.5% by volume to 23.5% by volume. “The fact that OSHA does not [...]

By |2025-05-01T09:33:23-05:00May 1st, 2025|Procedures, Workplace Safety|0 Comments

“OSHA Says”: Thermal Exposure

“If you can’t take the heat, get out of the kitchen.”  — Harry S. Truman For decades, I’ve told people that OSHA requires thermal protection on surfaces over 140°F (60 C) up to a height of 7 feet. People just accepted that because a) I was the expert and b) it made sense. Recently, though, [...]

By |2025-04-10T09:46:58-05:00April 10th, 2025|PHA, Process Safety, Risk Assessment, Workplace Safety|Comments Off on “OSHA Says”: Thermal Exposure

Process Safety: On the Bourbon Trail

“Devils drinking devils and the flames are getting higher. All of Bardstown’s crying tonight, Heaven Hill’s on fire.”  — Shannon Lawson, The Galoots Chris Schmidt and I recently returned from a week-long trip to Kentucky to enjoy the countryside and to sample bourbons from some of the 46 distilleries on the Kentucky Bourbon Trail. As [...]

“It’s Probably Water”: Is That Good Enough?

“You can’t trust water. Even a straight stick turns crooked in it.”  — W. C. Fields ChrisSchmidt and I recently visited several distilleries on Kentucky’s Bourbon Trail. After tasting one particularly strong whiskey, she reached for a tall glass of clear liquid to chase it down. “Yeah, that’s probably water,” said our tasting guide, hinting [...]

By |2025-03-27T08:31:27-05:00March 27th, 2025|Chemicals, Process Safety, Process Safety Management, Workplace Safety|Comments Off on “It’s Probably Water”: Is That Good Enough?

Falls: When PPE Is All You Have

“You may reasonably expect a man to walk a tightrope safely for ten minutes; it would be unreasonable to do so without accident for two hundred years.”  — Bertrand Russell Many of us face a dilemma when it comes to fall hazards. Particularly when it comes to maintenance. The hazards are unavoidable, the consequences of [...]

By |2025-02-20T10:08:14-06:00February 20th, 2025|Risk Assessment, Workplace Safety|Comments Off on Falls: When PPE Is All You Have

Bad Ideas: Abolishing OSHA

“The Occupational Safety and Health Act of 1970 is repealed. The Occupational Safety and Health Administration is abolished.”  — the complete text of Section 2 of H.R. 86, introduced by Rep. Andy Biggs (R-AZ) I’m not really sure what Andy Biggs hoped to accomplish by introducing his “Nullify Occupational Safety and Health Administration Act” (NOSHA [...]

By |2025-02-14T08:37:59-06:00February 13th, 2025|Current Events, Workplace Safety|Comments Off on Bad Ideas: Abolishing OSHA

Occupational Noise: Is Hearing Protection Enough?

“Unnecessary noise is the most cruel absence of care that can be inflicted on the sick or the well.”  — Florence Nightingale I grew up in an age of loud rock ‘n roll. I, like one in six people of my generation, suffer some hearing loss. To save the hearing that I still have, I [...]

By |2025-02-06T09:54:11-06:00February 6th, 2025|Recommendations, Risk Assessment, Workplace Safety|Comments Off on Occupational Noise: Is Hearing Protection Enough?

“OSHA Says”: Oxygen Monitoring

“Beware of false knowledge; it is more dangerous than ignorance.”  — George Bernard Shaw Because of the work we do, we often hear about OSHA requirements that don’t actually exist. Something akin to, “Well, OSHA says you have to…” Occasionally, they are right. More often though, the requirement fulfills someone’s agenda and OSHA is the [...]

By |2025-01-30T09:00:50-06:00January 30th, 2025|Process Safety, Workplace Safety|Comments Off on “OSHA Says”: Oxygen Monitoring

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|Comments Off on Tick Tock, Tick Tock: Is It Time for a PHA Revalidation?
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