“A rule without exceptions is an instrument capable of doing mischief to the innocent and bringing grief—as well as injustice—to those who should gain exemptions from the rule’s functioning.” — Derrick Bell I don’t remember when I first realized that there is a difference between process safety management and Process Safety Management. Process safety—the aspect [...]
“We cannot do everything at once, but we can do something at once.” — Calvin Coolidge I love a good play on words. “At once” can mean either “simultaneously” or it can mean “immediately”, and Calvin Coolidge managed to pack both meanings into a single sentence. “We cannot do everything simultaneously, but we can do [...]
“We must be part of the general staff at the inception, rather than the ambulance drivers at the bitter end.” — Lane Kirkland Despite being established under the authority of the Clean Air Act Amendments of 1990, which has not been repealed, the Trump administration intends to discontinue funding the Chemical Safety Board as of [...]
“A memorandum is not to inform the reader but to protect the writer.” — Dean Acheson A reader asked me “How long do I need to keep confined space entry permits for a covered process?” He knew my thoughts on retaining hot work permits and wondered if the same approach applied to other permits in [...]
“Quantity and persistence will get you the outcomes you need.” — James Altucher One of the challenges of process hazard analysis is risk assessment. To determine whether additional risk reduction is required, the team must quantify the risk and compare it to risk tolerance criteria. For the risk tolerance criteria to be useful to the [...]
“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 [...]
“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 [...]
“Every man is guilty of all the good he did not do.” — Voltaire Early in my career, our boss assigned a colleague and me to investigate an incident that was still having a significant impact on the plant. Being an arrogant know-it-all, I mean, an engineer, I was confident that I already knew what [...]
“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 [...]
“You can’t let your failures define you. You have to let your failures teach you.” — Barack Obama Forty years ago, on December 3, 1984, the Union Carbide plant in Bhopal, India released 45 tons of methyl isocyanate. The official toll of immediate deaths is 2,259 people. Estimates of the final death toll ranges but [...]
