“When one is up to his ass in alligators, it is easy to forget that his original objective was to drain the swamp.” — William Moore Thanks to the COVID-19 pandemic, just about every person in the world now knows that PPE stands for personal protective equipment. But instead of thinking about hardhats and steel-toed [...]
“What’s the use you learning to do right when it’s troublesome to do right and ain’t no trouble to do wrong, and the wages is just the same?” — Mark Twain, in The Adventures of Huckleberry Finn We love to hate regulations. The harder it is to comply with them, the more we hate them. [...]
“Life is a journey and not a destination.” — Lynn H. Hough When Richard Nixon signed OSHA into law in 1970, the United States was looking at 14,000 work-related fatalities per year. With a workforce of about 70 million full-time equivalents, the work-related fatality rate was about 20 fatalities per 200,000,000 hours worked. In 2018, [...]
“All I know is what I read in the papers.” — Will Rogers When there is a catastrophic release of highly hazardous chemicals, I want to know about it. I want to know what happened, why it happened, and what I can learn to keep it from happening again. I go to news accounts. All [...]
“Nor should participation trophies be offered for simply showing up.” — Kevin Dickenson OSHA is fond of pointing out that the Process Safety Management Standard, 29 CFR-1910.119 (PSM), is a performance-based standard. While they generally avoid telling us how to comply with standard, they expect us to comply with standard, nonetheless. There is no prize [...]
“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 [...]
“Human genius has limits, but stupidity does not.” — Alexandre Dumas, fils Everyone we have ever worked with is accepting, if not downright enthusiastic, about managing process safety. Likewise, everyone we have ever worked with is no more enthusiastic about complying with Process Safety Management than they are about getting a root canal. In part, [...]
“Archeology is the search for fact, not truth. If it’s truth you’re looking for, Dr. Tyree’s philosophy class is right down the hall.” — Indiana Jones, from The Last Crusade A process hazard analysis (PHA) is not a trivial exercise. The search for process hazards takes time and effort, and it pulls a team of [...]
“Unlike Humpty Dumpty, the Secretary may not give a word whatever meaning she chooses.” —Judge Richard DeBenedetto When the Meer Corporation took the bold and relatively unheard-of step of contesting an OSHA citation for violating the Process Safety Management standard (PSM), no one expected them to prevail. The PSM standard includes an exemption for atmospheric [...]
“This program is an enforcement tool to emphasize the obligations under existing OSHA standards,” – Kimberly Stille, OSHA Region VII Administrator When the West Fertilizer ammonium nitrate warehouse north of Waco, Texas caught fire and then blew up on April 17, 2013, killing 15 and injuring 160, much was made of the lack of inspections [...]
