Archive for the ‘Regulations’ Category

PSM 15th Element: Quality

Thursday, July 22nd, 2010

OSHA Process Safety Management (PSM) program is nearly two decades old and I believe that the 14 PSM elements provide a good basic framework for facilities to create a safety program. What OSHA PSM lacks is quality metric. Let me explain further. For example, one of the elements of the OSHA PSM is emergency planning. As a part of ...

How Risk Perception Affects Regulations

Monday, July 12th, 2010

Risk is a perception. Our perception of risks is mainly affected by two factors: (a) whether we are voluntarily accepting the risk.  A good example is a refinery worker considers the risks at workplace lower than his cousin who has only read about chemical plants; and (b) potential consequences of event or act or decision. For a layman, ...

Should the Cop Ticket Fred? Perils of Performance-Based Regulations

Wednesday, July 7th, 2010

When you are driving on a highway, usually there is a speed limit. If you exceed this limit, a cop can give you a ticket. In Houston, most highways have a speed limit of 65-70 miles per hour…although most drivers appear to assume it implies “90-mph is okay”. Let us say the ...

New Safety and Environmental Management System (SEMS) from MMS

Tuesday, June 29th, 2010

About a year ago, the Minerals Management Services (MMS) proposed a new rule that would require operators of oil and gas operations in the US Outer Continental Shelf to develop and implement Safety and Environmental Management System (SEMS). It is expected that the rule will be promulgated sometime this year. Based on ...

Train To Bhopal

Friday, June 11th, 2010

In Dec. of 2004, I attended a conference in India to commemorate 20 years of Bhopal. After the conference, a few attendees took a train to Bhopal to visit the plant site. While in Bopal I visited my aunt - her name is Maya. She was in her house in Bhopal ...

OSHA Combustible Dust Rulemaking

Thursday, January 28th, 2010

Stakeholder Comments on OSHA Combustible Rulemaking from John Astad's blog.

Industrial Safety in Slumdog Millionaire Nation

Monday, October 19th, 2009

According to the International Labor Organization (ILO), there were 11 deaths every 100,000 workers in India in 2005. This number was two in the US and 0.01 in Japan. What is scary is that the number of fatalities may be significantly underestimated because of absence of a formal accident tracking ...

OSHA NEP Fines

Wednesday, October 14th, 2009

OSHA inspected 42 refineries between June 2007 - February 2009. Below is a summary of violations for 30 refineries. [Table=12] The average penalty for each violation is $ 5,650. The average penalty per refinery is $ 98,300. Contrast these numbers with $700 million that cost BP for fatality and personal injury claims related to ...

Is the Chemical Safety Board (CSB) Positively Impacting Process Safety?

Wednesday, October 7th, 2009

CSB’s approach to chemical accident investigation is a step further than OSHA’s. CSB gathers background information about the accidents, performs a detailed root cause study, and makes recommendations to appropriate stakeholders. Great approach to a complex issue...but CSB’s strategy following the investigation leaves a lot to be desired. The hope from ...

Where’s the Training Material from OSHA Grants?

Monday, October 5th, 2009

Interesting post by John "Dust Explosion" Astad. Where's the Beef? Previous Training Material