Breaking Up Is Hard to Do: HazOp Nodes

“Come on, baby, let’s start anew, ‘cause breaking up is hard to do.”  — Neil Sedaka Before a HazOp team ever assembles, the facilitator has some important tasks to complete: get agreement with management on the scope of the review, identify the boundaries of the study, and break the process up into nodes.  And breaking [...]

By |2020-01-09T16:34:36+00:00January 9th, 2020|PHA, Procedures, Process Safety Management|1 Comment

2018 BLS Fatality Report: Has Anything Changed?

“The more things change, the more they remain the same.”  — Jean-Baptiste Alphonse Karr When I was a young engineer living in a small town in central Massachusetts, I would walk into the town center to pick up groceries and go to the post office. On the way, there was a body shop. I got [...]

By |2019-12-26T16:34:36+00:00December 26th, 2019|Workplace Safety|0 Comments

Everyone Gets a Prize: Employee Participation

“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 [...]

By |2019-12-12T15:11:38+00:00December 12th, 2019|Procedures, Process Safety Management|1 Comment

Inconceivable: Unrecognized Hazards

“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 [...]

By |2019-12-05T14:08:07+00:00December 5th, 2019|Process Safety, Risk Assessment, Safety Lifecycle|1 Comment

Out of the Blocks: Credit for Human Response

“Fear is often our immediate response to uncertainty.”  — Gabrielle Bernstein In 2001, when the CCPS book, Layer of Protection Analysis: Simplified Process Risk Assessment, “the purple book”, stated that human response is “a relatively weak protection layer” and “less reliable than engineering controls”, many people were willing to accept that piece of conventional wisdom. [...]

Size Matters: Sampling for PSM Compliance Audits

“Facts are stubborn things, but statistics are more pliable.”  — Oscar G. Foellinger, 1927 As an engineering student, I once used empirical data to solve a design problem. The approach gave a reasonable answer, but my professor scolded me. “Mere curve fitting,” he sneered. “Good engineering requires working from first principles.” I didn’t agree then, [...]

By |2019-10-24T15:20:35+00:00October 24th, 2019|Process Safety|0 Comments

We’re Not Wizards

“But how they can be charged with negligence because they were not wizards, appellant’s brief does not make clear.”  — Osmond K. Fraenkel, successfully arguing before the New York Supreme Court, 1935 In a world where companies tout “Zero Incidents,” not as an aspirational definition of perfect safety, but as a measurable and achievable target, [...]

Someone Else’s Experience

“Experience: that most brutal of teachers. But you learn, my God do you learn.”  — C.S.Lewis We all learn from experience. When it comes to brutal lessons, though, it is better to learn from someone else’s experience.  In the course of our work, clients have shared some experiences with us that everyone can learn from.  [...]

By |2019-09-26T13:14:16+00:00September 26th, 2019|Process Safety, Workplace Safety|0 Comments

PSM Auditor: Coach or Umpire?

“Umpires don’t make the rules.  They apply them…They make sure everybody plays by the rules.  But it is a limited role.  Nobody ever went to a ballgame to see the umpire.”  — Supreme Court Chief Justice John Roberts A call about doing a PSM audit usually begins with a question from the caller about whether [...]

Seven Questions: The Essence of HazOps

“A prudent question is one-half of wisdom.”  — Francis Bacon There are about a gazillion “best” ways to do HazOps. What they all have in common, however, is that they use worksheets that are set up as tables that look at deviations in a node. For each deviation, a HazOp team considers “Causes”, “Consequences”, “Safeguards”, [...]

By |2019-08-29T14:38:07+00:00August 29th, 2019|PHA, Process Safety, Process Safety Management|0 Comments