The Elements of PSM: Trade Secrets

“This hour I tell things in confidence. I might not tell everybody, but I will tell you.”  — Walt Whitman I once worked at a plant that produced performance chemicals. Performance chemicals are sold based on what they do rather than what they are. The key specifications are the performance specifications, not the composition specifications. [...]

By |2026-09-03T14:54:33-05:00September 3rd, 2026|Chemicals, Process Safety, Process Safety Management|0 Comments

STAA: Just a Little Bit Longer

“Because things are the way they are, things will not stay the way they are.”  — Bertolt Brecht Of all the recent revisions to the EPA’s Risk Management Planning (RMP) rule, 40 CFR 68, the requirements around Safer Technology and Alternatives Analysis (STAA) have probably gotten the most attention. For those facilities covered by Program [...]

By |2025-01-14T13:52:03-06:00October 18th, 2024|Chemicals, Current Events, PHA, Safety Lifecycle|Comments Off on STAA: Just a Little Bit Longer

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 [...]

By |2025-01-17T10:38:58-06:00September 19th, 2019|Process Safety, Process Safety Management, Recommendations, Safety Lifecycle|Comments Off on PSM Auditor: Coach or Umpire?

Your Next Blockbuster Adventure: The PHA

“Archeology is the search for fact, not truth. If it’s truth you’re looking for, Dr. Tyree’s philosophy class is right down the hall.” — Indiana Jones, from The Last Crusade A process hazard analysis (PHA) is not a trivial exercise.  The search for process hazards takes time and effort, and it pulls a team of [...]

By |2025-01-17T11:09:43-06:00January 31st, 2019|PHA, Process Safety, Process Safety Management|Comments Off on Your Next Blockbuster Adventure: The PHA

A New Enforcement Program: Ammonia and Ammonium Nitrate

“This program is an enforcement tool to emphasize the obligations under existing OSHA standards,”  – Kimberly Stille, OSHA Region VII Administrator When the West Fertilizer ammonium nitrate warehouse north of Waco, Texas caught fire and then blew up on April 17, 2013, killing 15 and injuring 160, much was made of the lack of inspections [...]

By |2025-01-17T11:33:17-06:00October 4th, 2018|Chemicals, Current Events, Process Safety, Process Safety Management|Comments Off on A New Enforcement Program: Ammonia and Ammonium Nitrate

Will Trump Reverse the EPA’s Revised RMP Rules?

“From this day forward, a new vision will govern our land.”  President Donald J. Trump President Trump just reversed the Obama administration’s rejection of the Keystone XL pipeline.  Regardless of my concerns about hydrocarbon consumption, as a safety professional, I have to welcome the news, knowing as I do that pipelines are the safest way [...]

By |2025-01-17T12:59:31-06:00January 26th, 2017|Current Events, Process Safety|Comments Off on Will Trump Reverse the EPA’s Revised RMP Rules?
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