Are Boilers PSM-Covered? Maybe, Maybe Not

“It’s very hard for all of us, when we’ve committed ourselves to a particular interpretation, to change our minds.”  — Donald Johanson We were recently asked if a steam boiler was a PSM-covered process. The answer seemed obvious. No, steam boilers, themselves, are not covered under the Occupational Safety and Health Administration’s Process Safety Management [...]

By |2022-05-19T15:16:51+00:00May 19th, 2022|Process Safety, Process Safety Management|Comments Off on Are Boilers PSM-Covered? Maybe, Maybe Not

Occupancy: Getting It Right

“I don’t worry about the bullet with my name on it. Can’t do anything about that. It’s the bullet addressed to ‘Occupant’ that I worry about.”  — Drew Schmidt I don’t get as much junk mail as I used to.  Now, I get junk emails and junk texts. When I do get junk mail, however, [...]

By |2022-03-10T18:38:15+00:00March 10th, 2022|PHA, Process Safety, Process Safety Management|Comments Off on Occupancy: Getting It Right

Process Risk: Learning from Experience

“We do not learn from experience…we learn from reflecting on experience.”  — John Dewey There are too many celebrities and philosophers to count who have talked about the importance of their mistakes in shaping them. Many seem quite pleased, even proud, of the mistakes they’ve made and their ability to rise from them and go [...]

By |2022-02-24T14:56:55+00:00February 24th, 2022|PHA, Process Safety, Workplace Safety|Comments Off on Process Risk: Learning from Experience

The Supreme Court and Process Safety

“That is not to say OSHA lacks authority to regulate occupation-specific risks related to COVID–19.”  — Brett Kavanaugh It’s not often that the courts weigh in on safety issues. Thank goodness. As Sidney Dekker points out in his book, Just Culture, the involvement of the justice system is bad for safety. It leads to less [...]

By |2022-01-20T15:41:13+00:00January 20th, 2022|Current Events, Process Safety, Workplace Safety|Comments Off on The Supreme Court and Process Safety

Risk Reduction: Any Credit for Mechanical Integrity?

“People give us credit only for what we ourselves believe.”  — Karl Gutzkow Several years ago, in a paper and presentation to the Global Congress on Process Safety (GCPS), PSM experts from OSHA observed that while it is common to see a mechanical integrity (MI) program listed as a safeguard in a PHA, this is [...]

By |2021-12-09T16:27:42+00:00December 9th, 2021|PHA, Process Safety Management, Risk Assessment, Workplace Safety|Comments Off on Risk Reduction: Any Credit for Mechanical Integrity?

Safety Training: Why Do We Hate It?

“I wish we had more safety training.”  — No one. Ever. Have you ever had a coworker respond, “You are so lucky,” when you told them that you had some mandatory safety training coming up? No? When it comes to safety training, isn’t the word “mandatory” redundant? Have you ever attended or even been offered [...]

By |2021-09-17T12:55:04+00:00September 16th, 2021|Training, Workplace Safety|Comments Off on Safety Training: Why Do We Hate It?

Storage Tanks: Labeling Requirements

“Don’t rely too much on labels, for too often they are fables.”  — Charles Spurgeon Trick question: “What does PSM require for storage tank labeling?” Trick answer: “Nothing.” Helpful answer: “OSHA doesn’t require storage tank labeling under the Process Safety Management (PSM) standard, 29 CFR 1910.119. It does, however, have requirements for storage tank labeling [...]

Slightly Flammable? Low GWP Refrigerants and PSM

“You can’t get a little bit pregnant, son.”  — Hal Holbrook as Lou Mannheim in Wall Street, (1987) A whole new group of processes are about to become PSM-covered. Maybe. Some HVAC contractors have begun warning their customers that the new low-GWP refrigerants that they must switch to are “slightly flammable”, so may come under [...]

By |2021-05-13T14:04:07+00:00May 13th, 2021|Current Events, Gas, Process Safety, Process Safety Management|Comments Off on Slightly Flammable? Low GWP Refrigerants and PSM

DHAs: An OSHA Requirement?

“Speed limit 55. It’s not just a good idea. It’s the law.”  — Advertising Council and U.S. Department of Transportation (1977) Ever since the National Fire Protection Association (NFPA) published the 2019 Edition of NFPA 652, Standard on the Fundamentals of Combustible Dust, which states in §7.1.1.2 that a Dust Hazard Analysis (DHA) must be [...]

By |2021-04-29T16:43:06+00:00April 29th, 2021|Combustible Dust, Process Safety, Process Safety Management|Comments Off on DHAs: An OSHA Requirement?

The Next Thing You Know: PSM-Covered Warehousing

“On the first day of school, you got to be real careful where you sit. You walk into the classroom and just plunk your stuff down on any old desk, and the next thing you know the teacher is saying, ‘I hope you all like where you’re sitting, because these are your permanent seats.’”  — [...]

By |2021-04-22T15:39:29+00:00April 22nd, 2021|Chemicals, Process Safety, Process Safety Management|Comments Off on The Next Thing You Know: PSM-Covered Warehousing
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