Recognizing Hazards: Nickel Carbonyl

“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 [...]

By |2026-03-27T12:48:50-05:00March 27th, 2026|Chemicals, Process Safety|1 Comment

Bad Chemistry: Energetic Decomposition

“Everything that comes together falls apart.”  — John Green When we think of decomposition, we usually think of it as a slow, inexorable process of breaking down useful things into malodorous glop. Think of that six-month-old head of lettuce in the bottom of the refrigerator. Or the carcass of the dead animal in the woods, [...]

By |2026-03-19T15:04:44-05:00March 19th, 2026|Chemicals, Process Safety|Comments Off on Bad Chemistry: Energetic Decomposition

Chemical Incidents: Top Three Reasons

“Always lists to be made, as if writing items in neat vertical rows might stave off randomness and chaos.” — Dani Shapiro People love lists. Top Ten Lists. Top Twelve Lists. Casey Kasem’s American Top Forty. And for those with short attention spans, Top Three Lists. I recently received an email asking if I agreed [...]

By |2026-02-19T10:57:40-06:00February 19th, 2026|Chemicals, Process Safety, Process Safety Management, Workplace Safety|Comments Off on Chemical Incidents: Top Three Reasons

Incident Investigations: When Are They Needed?

“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 [...]

By |2026-02-06T14:52:33-06:00February 6th, 2026|Procedures, Process Safety, Process Safety Management, Workplace Safety|Comments Off on Incident Investigations: When Are They Needed?

Process Safety: When “Normal” Isn’t Normal

“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 [...]

By |2026-01-29T11:00:03-06:00January 29th, 2026|Procedures, Process Safety, Process Safety Management|Comments Off on Process Safety: When “Normal” Isn’t Normal

“OSHA Says”: Making a List, Checking It Twice

“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 [...]

By |2026-01-14T18:26:57-06:00December 18th, 2025|Craft Distillery Safety, Procedures, Process Safety, Process Safety Management, Workplace Safety|Comments Off on “OSHA Says”: Making a List, Checking It Twice

The PSM Standard: Are Craft Distilleries Covered?

“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 [...]

By |2025-11-06T11:11:04-06:00October 23rd, 2025|Chemicals, Craft Distillery Safety, Process Safety, Process Safety Management|Comments Off on The PSM Standard: Are Craft Distilleries Covered?

OSHA Says: Promptly, Timely, and As Soon As Possible

“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 [...]

By |2025-09-29T11:52:57-05:00September 26th, 2025|PHA, Process Safety, Process Safety Management|Comments Off on OSHA Says: Promptly, Timely, and As Soon As Possible

CSB Incident Reports: Volume 3

“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 [...]

By |2025-08-07T11:01:32-05:00August 7th, 2025|Current Events, Process Safety, Process Safety Management, Workplace Safety|Comments Off on CSB Incident Reports: Volume 3

Recordkeeping for Process Safety: Permit Retention

“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 [...]

By |2025-07-10T09:32:30-05:00July 10th, 2025|Procedures, Process Safety, Process Safety Management|Comments Off on Recordkeeping for Process Safety: Permit Retention
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