Process Safety Blog

EPA’s Risk Management Program (RMP) Reconsideration final rule

December 2, 2019

There were recently important changes made to the Environmental Protection Agency’s Risk Management Program (RMP).  On November 20, 2019, EPA Administrator Andrew Wheeler signed the Risk Management Program Reconsideration final rule to “better address potential security risks, regulatory consistency and reasonable consideration of costs.”   The EPA first proposed these changes to its RMP back in […]

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How about a stage zero functional safety assessment (FSA)?

November 3, 2019

Inspired by “Conducting an Effective Functional Safety Assessment” presented at 2019 ISA PIC 2019—Process Industry Conference.   The ISA/IEC 61511 standard defines a functional safety assessment as [an] “investigation, based on evidence, to judge the functional safety achieved by one or more safety instrumented systems and/or other protection layers.” The standard describes five stages where […]

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A problem (and solution) with estimating rare event frequencies

October 21, 2019

Industry uses many numbers in process safety associated with predicting the likelihood of rare, catastrophic events (e.g., failure rates, demand rates, incident rates, probability of failure, probability of ignition, etc.). Yet have you given serious thought to the accuracy and trustworthiness of those numbers? For example, layer of protection analysis (LOPA) often uses target numbers […]

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The top 5 reasons why people don’t want to evaluate human factors and barrier reliability… but should

July 29, 2019

The concept of barriers as discrete layers consisting of administrative controls, alarms, instruments, mechanical devices, and post‐release mitigation is highly idealized. It may in fact be misleading because it blinds us to the reality that all barriers rely on people. These groups of people consist of operations, maintenance, technical staff, contractors, and management. These groups […]

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Test the Integrity of your Process Safety Program with a Drill Down Audit

June 5, 2019

A hazard scenario-based, drill-down audit can uncover systematic issues brewing beneath the surface not often uncovered from a traditional compliance audit. This methodology exposes the pain points and, most importantly, the sources of those points by digging deep into the management system processes around Process Hazard Analysis (PHA)/Layer of Protection Analysis (LOPA), Process Safety Information […]

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Process Safety Management, Jenga, Drift, and Preventing Process Industry Accidents

December 20, 2018

Blog by Paul Gruhn, P.E., CFSE, Global Functional Safety Consultant, aeSolutions       Have we really learned anything from previous accidents? There have been many well publicized process industry accidents over the last several decades. Articles and books have been written about many of these events. However, most books essentially reviewed what happened the […]

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RMP Reconsideration Rule Issued by the EPA

May 25, 2018

On Thursday, May 17, 2018, EPA Administrator Scott Pruitt signed a proposed rule requesting comment on proposed changes to the final RMP Amendments (40 CFR Part 68) which have a delayed effective date of February 2019. The proposed rule would rescind several of the amendments proposed in January 2017. The RMP Reconsideration Rule proposes the […]

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