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Just what is required for a High-hazard Group H occupancy?
High-Hazard Group H Occupancy High-hazard Group H occupancy includes, among others, the use of a building or structure, or a portion thereof, that involves the manufacturing, processing, generation or storage of materials that constitute a physical or health hazard. Hazardous occupancies are classified in Groups H-1, H-2, H-3, H-4 and H-5. High-hazard Group H-1 buildings and structures that contain materials that pose a detonation (explosion) hazard. Here is a summary of the requirements and their code citations: Membership Content
How an MOC can avoid reacordable injuries/illnesses
Much like it is in process safety, the Management of Change (MOC) tool may be the most despised element of an SMS. However, a recent safety assessment with a local client identified the lack of performing an MOC on significant changes to production machinery and rates. The facility is NOT a PSM facility, but they are ISO45001 "certified." Last year, the facility had four (4) recordable hearing loss cases (e.g., a loss of 25 dBs), which got corporate asking questions. I was contacted to see if I could investigate and determine the causes that led to these recordable illnesses. Of course, I started with the written HCP and all the required actions the plan calls for. I immediately noticed that the facility's HCP stated an attenuation evaluation would be done for each type of HP provided; the facility had not conducted this evaluation. As it turns out, the HP being provided could only attenuate exposures to less than 90 dBA, not the required 85 dBA for those who had suffered an STS. And almost 50% of the employees in the HCP had suffered an STS over the previous three (3) years -YES, that is very high percentage! I then went to the exposure data, where the wheels came off! The facility had undergone many "improvements" and growth over the previous four (4) years. The business consolidated three facilities into one and moved into a new building. However, the business has not updated its Noise Survey and Personal Sampling with the new building and equipment layouts. Add this to the fact that the HP being provided was inadequate! The business immediately hired an IH firm to come in and perform some noise sampling to establish exposures. Management was not happy and began to point fingers at the OSH manager. But this professional had plenty of evidence that he/she had made it clear that a new building, new machines, new layout of the machines, etc. would need an MOC to manage this change. Remember, this is an ISO45001 certified facility. Understanding the basics of the ABC model is a MUST for safety professionals
Understanding the basics of the ABC model is a MUST for safety professionals, even if your organization is not ready for a formal Behavior Based Safety Process (BBSP). This simple model will enlighten many and help them understand WHY workers and management do what they do. Seasoned safety pros will often focus far too much on the Behaviors and Consequences when, in fact, it is the Activators (or Antecedents) that offer us so much opportunity for improvement. Several years ago, I read Clive Lloyd's book Next Generation Safety Leadership: From Compliance to Care, where he coined the phrase: Behaviors are not the problem; they are a reflection of the problem. Oh, how I wish I could have read that book in 1995 or heard that phrase, as it could have saved me a lot of "growing pains" as I navigated the choppy waters of implementing BBSPs and focusing too much on the observed behaviors and consequences and far too little on the activators that were driving those observable behaviors. Believe it or not, a Causal Analysis course I took in 1996 changed how I view behaviors and decision-making. In that course, then supported by all the Plant Managers I worked for, we learned to focus on the Latent Organizational Failures more than the Active Failures, and by doing so, we created Corrective Action Plans (CAPs) that were designed to address the "activators" rather than the behavior. By the way, the two (2) books that I will suggest that every safety professional must read are:
Both books are easy to read and will profoundly impact your approach to managing safety, especially Behavior Based Safety matters. So, let's discuss the ABC model and how each element can improve safety performance and culture. Inspections vs Audits
The words "audits" and "inspections" often get used as if they are the same thing - THEY ARE NOT the same. I always like to say we inspect "things," and we audit those inspections. Much like my previous post earlier this month, explaining the difference between "examinations" and "inspections" as used in ASME B31 series; the terms have different meanings and we need to understand these differences. For example, we inspect our fire extinguishers monthly, but how often are we auditing those inspections? Inspections can become a "pencil whipping" exercise, as I am sure many of you have experienced. To avoid this from causing a failure in our layers of protection, we should "audit" those fire extinguisher inspections to verify that they are being done and to validate the data coming from those inspections. Another way of saying this is from the QMS mindset.... we inspect objects and audit processes. SMS Auditing: 1st Party, 2nd Party, 3rd Party
One of the more critical elements of an SMS is "auditing." In the Plan-Do-Check-Act model, auditing falls within the "CHECK" function. I like to say it's the element that keeps us honest and informed. And with that in mind, I break down my audits into three (3) layers: → 1st Party → 2nd Party → 3rd Party Each type of audit has its pros and cons, and the fact that the facility is auditing is critical; who is doing it plays a role, but not as critical. Here is how these audits work: Old secondary containment design vs. New secondary containment design
In the old days, the secondary containment around flammable liquid storage tanks could be a single system in which all the storage tanks sat. Today, that is NOT the case. Both NPFA 30 and IFC Chapter 57 require the secondary containment to be such that an LOPC from one tank can NOT impact the other tanks around it. They use the word "subdivided" to specify this. (emphasis by me) [My Safety] Thought of the Week... the SIF approach
If your team is focused on an event's probability or likelihood, you're NOT doing SIF! The Serious Injuries and Fatalities (SIF) model is intended to IDENTIFY events that have opportunities to cause life-altering injuries and death. And yes, most of these will (hopefully) have LOW frequencies/probabilities. So, to justify NOT responding to these LOW frequency - HIGH severity events by simply stating their likelihood is LOW is the opposite of the SIF model approach. If you are a facility that has a PSM/RMP management system, guess what? You're already utilizing the SIF model, as both PSM and RMP are safety management systems designed to manage LOW frequency — HIGH severity events. Using the same management system tools will drive the same improvements outside of the PSM/RMP Battery Limits. Safety Thought of the Week... Barrier/Controls/Safeguards Management
The purpose of barrier[/controls/safeguards] management is to make the kind of implicit controls explicit: to be clear about exactly
Source: Human Factors in Barrier Management, Prepared by a CIEHF Working Group comprising: Ron McLeod, Ian Randle, Rob Miles, Ian Hamilton, John Wilkinson, Christine Tomlinson, Gyuchan Thomas Jun, Tony Wynn. December 2016 Line Break gone bad (Cl2 cylinder change)
Eight people, including five (5) contract workers and three (3) fire service personnel, were admitted to the hospital after they inhaled chlorine gas following a leakage at a water treatment plant. EPA RMP citations @ chlorine, bleach, and hydrochloric acid facility (Cl2, H2, HCL & $264K w/ $363K SEP)
Respondent operated a facility (the “Facility”) to manufacture chlorine, bleach, and hydrochloric acid. Respondent produced, used, or stored more than 2,500 pounds of chlorine at the Facility and was subject to the requirements of CAA § 112(r)(7). Respondent produced, used, or stored hydrogen at the Facility and was subject to the requirements of CAA § 112(r)(1). Respondent was subject to Program 3 requirements because it had public receptors near the endpoint for the worst-case release and was subject to the OSHA process safety management standard set forth in 29 C.F.R. § 1910.119. Based upon the information gathered during the Investigation, EPA determined that Respondent violated certain provisions of the CAA. |
Partner Organizations
I am proud to announce that The Chlorine Institute and SAFTENG have extended our"Partners in Safety" agreement for another year (2024) CI Members, send me an e-mail to request your FREE SAFTENG membership
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