“The only thing that saves us from bureaucracy is its inefficiency. An efficient bureaucracy is the greatest threat to liberty.” — Eugene McCarthy A client recently posed this question: “Why do you think the EPA is more willing to update its regulations than OSHA?” Is it? We gave a glib answer – resources – but [...]
“Ambivalence is like carbon monoxide – undetectable yet deadly.” — Cherie Carter-Scott World Fertilizer published an article in its March 2026 issue on “An Overlooked Process Hazard” in the production of ammonia fertilizers. It seems to me that this hazard has broader implications, beyond fertilizer production. Flammable liquids and flammable gases are all covered by [...]
“It seems to me that at this time we need education in the obvious more than investigation of the obscure.” — Oliver Wendell Holmes, Jr. OSHA requires incident reports. For recordable injuries or illnesses, OSHA requires that a 301 Form, Injury and Illness Incident Report, be completed, per 29 CFR 1904.29(a). For workplaces with PSM-covered [...]
“You keep using that word. I do not think it means what you think it means.” — Mandy Patinkin as Inigo Montoya from The Princess Bride (1987) I, like many older Americans, worry about my blood pressure enough to check it regularly. And like most people who check their blood pressure regularly, I know what [...]
“I have so much paperwork. I’m afraid my paperwork has paperwork.” — Gabrielle Zevin One of the key differences between OSHA’s Process Safety Management (PSM) standard and the EPA’s Risk Management Planning (RMP) rule is the RMP rule’s requirement to submit documentation to the EPA. OSHA has no similar requirement for submission. If OSHA wants [...]
“You know what’s the greatest part of anything ever in the history of everything? Exaggeration. No wait; it’s correcting yourself. No, better yet, it’s making lists.” — Demetri Martin When Google offers an AI response, it includes a statement: “AI responses may include mistakes.” That was never so obvious to me as when I posed [...]
“We sometimes freeze the specimen with liquid nitrogen, which is extremely cold, you know. This is another technique we use now – but the specimens are not alive.” — Lennart Nilsson I recently facilitated a HazOp where the process required both very hot heat transfer media (steam and hot oil) and very cold heat transfer [...]
“It is your concern when your neighbor’s wall is on fire.” — Horace On November 26, 2025, a fire enveloped a high-rise apartment in the Wang Fuk Court complex that was undergoing significant renovation. The fire killed at least 159 people and took the Hong Kong fire department almost two full days to extinguish. Hong [...]
“Don’t be misled by History, or any other unreliable source.” — Will Rogers I remember when I lost faith in safety data sheets – SDSs. Well, they were called Material Safety Data Sheets – MSDSs – then. I was a young engineer, and the only engineer, at a start-up. My boss, the owner, assigned me [...]
“Before the first atomic bomb test, scientists took the time to calculate whether the blast would ignite the nitrogen in the Earth’s atmosphere and incinerate us all. The risk was low and the test went off, but Rees wonders what the odds would have had to be to discourage the bomb makers.” — Dennis Overbye [...]
