Exhaust Ducts: When Safeguards Have Their Own Hazards

“The guard shall be such that it does not offer an accident hazard in itself.”  — 29 CFR 1910.212(a)(2) Machine guarding It’s hard to imagine any safeguard that doesn’t pose its own burden. Safety shoes are heavy and make a worker less nimble. Side shields on safety glasses impair peripheral vision. Interlocks introduce the prospect [...]

By |2025-01-16T13:34:53-06:00January 19th, 2023|Process Safety, Workplace Safety|Comments Off on Exhaust Ducts: When Safeguards Have Their Own Hazards

Avoiding the Streetlight Effect: How Does the CPI Really Get Safer?

“The battle of getting better is never ending.”  — Antonio Brown There’s an old joke about someone looking for their keys under a streetlight. A passerby offered to help but after a while, asked, “Are you sure this is where you lost them?” “No, I lost them over there in the park.” “Then why are [...]

By |2025-01-16T13:36:59-06:00January 5th, 2023|Process Safety, Process Safety Management, Workplace Safety|Comments Off on Avoiding the Streetlight Effect: How Does the CPI Really Get Safer?

Process Safety: Tornadoes in December

“The potential changes to particular provisions of the current PSM standard that OSHA is considering include:  8. Clarifying paragraph (e) to require consideration of natural disasters and extreme temperatures in their PSM programs, in Response to E.O. 13990.”  — OSHA, 20-Sep-2022 call for Stakeholder comments I grew up in the Midwest. I’ve lived in Joplin, [...]

By |2025-01-16T13:40:02-06:00December 16th, 2022|Current Events, Procedures, Training, Workplace Safety|Comments Off on Process Safety: Tornadoes in December

PSM Documents: How Long Do I Have to Keep This Stuff?

“The entire health care system is now being organized around machines instead of human beings. Not prioritized to reduce human suffering, but rather to optimize a computerized recordkeeping system. This is a tragedy.”  — Carolyn Jourdan Imagine for a moment that you are a new PSM coordinator. The person who had the job before you [...]

By |2025-01-16T13:41:54-06:00December 1st, 2022|Process Safety, Process Safety Management|Comments Off on PSM Documents: How Long Do I Have to Keep This Stuff?

The Good Old Days: Never Again

“Nostalgia is a file that removes the rough edges from the good old days.”  — Doug Larson It’s hard to imagine the New York skyline without the Statue of Liberty. The Paris skyline without the Eiffel Tower. The San Francisco skyline without the Golden Gate Bridge. The Saint Louis skyline without the Gateway Arch. But [...]

By |2025-01-16T13:52:16-06:00November 3rd, 2022|Workplace Safety|1 Comment

Is There a Season of Death? Work-Related Fatalities

“For everything there is a season, and a time for every purpose under heaven. A time to be born and a time to die, a time to plant, and a time to harvest.”  — Ecclesiastes 3:1-2 When October rolls around and plans for Halloween are being made, thoughts often turn to autumn as a time [...]

By |2025-01-16T13:54:21-06:00October 27th, 2022|Workplace Safety|Comments Off on Is There a Season of Death? Work-Related Fatalities

Top 10 OSHA Violations: The Process Industries

“The human animal differs from the lesser primates in his passion for lists.”  — H. Allen Smith My first experience with lists was as a child, when I was frequently warned, “If you keep it up, you’re going to end up on Santa’s naughty list.” Now, lists seem inescapable. Shopping lists, checklists, reading lists. And [...]

By |2025-01-16T13:55:04-06:00October 20th, 2022|Current Events, Process Safety, Process Safety Management, Workplace Safety|Comments Off on Top 10 OSHA Violations: The Process Industries

Hearing Protection: Will Earbuds or Headphones Work?

“Hearing loss is a terrible thing because it cannot be repaired.”  — Pete Townshend “Why not?” The young operator had just asked if they could wear earbuds instead of ear plugs when they were out in the process. “I mean, as long as I’ve got something stuck in my ears, it might as well be [...]

By |2025-01-16T13:56:12-06:00October 13th, 2022|Workplace Safety|Comments Off on Hearing Protection: Will Earbuds or Headphones Work?

Time for Change: Revising the Elements of PSM

“The world hates change, yet it is the only thing that has brought progress.”  — Charles Kettering I just got notice from OSHA that I am registered as a participant in their upcoming stakeholder meeting about the changes to the PSM Standard that they are considering. I asked to speak and will get about three [...]

By |2025-01-16T13:58:35-06:00September 29th, 2022|Current Events, Process Safety, Process Safety Management|Comments Off on Time for Change: Revising the Elements of PSM

Spreading OSHA’s Wings: Expanding the Scope of PSM

“It must be remembered that there is nothing more difficult to plan, more doubtful of success, nor more dangerous to manage than a new system. For the initiator has the enmity of all who would profit by the preservation of the old institution and merely lukewarm defenders in those who gain by the new one.”  [...]

By |2025-01-16T13:59:32-06:00September 22nd, 2022|Current Events, Process Safety, Process Safety Management|Comments Off on Spreading OSHA’s Wings: Expanding the Scope of PSM
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