Managing Process Safety: Lessons from the Pandemic

“When a man knows he is to be hanged in a fortnight, it concentrates his mind wonderfully.”  — Samuel Johnson COVID-19, with its 14-day – fortnight – incubation period has had the effect of concentrating some of the best minds in the world. I have read several articles recently where the authors suggest how the [...]

By |2020-04-23T15:29:27+00:00April 23rd, 2020|Current Events, Process Safety|0 Comments

What If There Was No PSM Standard?

“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. [...]

By |2020-03-26T14:35:52+00:00March 26th, 2020|Process Safety, Process Safety Management|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

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

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 [...]

A Process Safety Hat Trick

“I hated being pregnant, but I never minded being in labor.  I knew I would get a prize at the end.”  — Chris Schmidt, mother of four Things have been a little crazy in Saint Louis for the past week. Founded in 1967, the Blues Hockey Club has finally won a Stanley Cup. Everyone feels [...]

Setting Limits: Where Does Your PSM-Covered Process End?

“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, [...]

Four Key Points: Applying the Meer Decision to Flammable Storage

“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 [...]

By |2018-11-01T18:32:21+00:00November 1st, 2018|Process Safety Management|0 Comments