Process Safety Blog

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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Upcoming HazCom Deadline and its Impact on RMP and PSM Compliance

April 4, 2016

In March 2012, the Occupational Safety and Health Administration (OSHA) revised the Hazard Communication (HazCom) Standard, 29 CFR 1910.1200, to align it with the United Nations Globally Harmonized System of Classification and Labelling of Chemicals (GHS), Revision 3. The revision to the HazCom Standard built on the existing standard, by requiring chemical manufacturers and importers […]

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USEPA Released Proposed Revisions to RMP Regulation (40 CFR Part 68)

March 2, 2016

The United States Environmental Protection Agency (USEPA) released a pre-publication of the proposed Risk Management Program (RMP) rule changes last week to be published in the Federal Register. Comments are due 60 days after the date of publication in the Federal Register. A public meeting is planned for March 29, 2016. The proposed revisions and […]

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Independent Protection Layers…Will they work when needed?

February 19, 2016

Layer of Protection Analysis (LOPA) has become an important tool used in industry, often in conjunction with a Process Hazard Analysis (PHA). It is used to evaluate high severity or high risk consequences with additional rigor of review to assess that safeguards and systems are adequately in place to meet the company’s risk tolerance requirements. […]

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