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Category Archives: System Optimization
Learning from Failure
“Failure is only opportunity to begin again. Only this time, more wisely.” –Henry Ford We often push PSM practitioners to perform Incident Investigations for fairly minor events in the hopes that the lessons learned from those minor incidents will stop … Continue reading
Posted in Culture, General Information, Good Engineering Practices, Incidents, OSHA, System Optimization
Tagged Incidents, Lessons Learned, OSHA, PSM, RAGAGEP, RMP
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Why we changed our element “Guidelines” to be called “Written Plans”
In mid-february we changed every reference to Guideline in the example templates to Written Plan. This change was made to the Google Drive and logged on 2/3/17. Although I have used guideline for a very long time, it was really just out of habit – it’s … Continue reading
Posted in General Information, Standardization, System Optimization
Tagged PSM, RMP, Standardization
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Management Of Change (MOC) for Personnel
In response to a recent LinkedIn forum post, here’s a short discussion on why MOC should be implemented for some personnel changes. 1910.119(l)(1) The employer shall establish and implement written procedures to manage changes (except for “replacements in kind”) to … Continue reading
Posted in Compliance, Management of Change, System Optimization
Tagged Management of Change, PSM, RMP
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Pencil-Whipping can Kill
What is it? Pencil-whipping is when you complete a form, record, or document without having performed the implied work or without supporting data or evidence. Here are some common examples in NH3 refrigeration: Completing “word orders” without conducting the work … Continue reading
Posted in Compliance, Culture, General Information, Incidents, Inspections, Mechanical Integrity, Operator Training, System Optimization
Tagged General, Incidents, Lessons Learned, Mechanical Integrity, Operator Training
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Opinion: Why many Safety Programs fail to get results
The question that vexed me Over the past few years as a traveling PSM auditor I was exposed to hundreds of different safety programs. There were small, flat organizations with dozens of workers and large international conglomerates with thousands of … Continue reading
Posted in Compliance, Culture, System Optimization
Tagged Emergency Action Plan, Employee Involvement, General, Lessons Learned
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How should I FIX a PSM program?
This might be one of the most common questions we’re asked: How do I resurrect a PSM program that has been neglected? Our answer is that you should deal with these broken programs no differently than if you are starting a … Continue reading
Posted in General Information, Standardization, System Optimization
Tagged General, PSM, RMP, Standardization
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First, Do no Harm!
The OSHA Law Blog has a nice post up called “Best Practices? Or Safety Run Amuck” about the unintended consequences that can occur when people rationalize their opinions as “Best Practice” without bothering to consult with the workers who are expected to … Continue reading
Posted in General Information, System Optimization
Tagged Employee Involvement, Humor, SOP
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A few links I wanted to share…
First up, S.K. Energy Consulting: There are some simple to understand articles on Floating Head Pressure and Optimizing Defrost. Check out the articles archives which contain almost 80 newsletters going back several years. Very informational site that I am surprised I … Continue reading
Posted in Compliance, General Information, Standardization, System Optimization
Tagged Efficiency, EPA, OSHA, PSM, RMP, Standardization
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Refresher Training
Many people struggle with Refresher Training. I think this is because the way they train to meet the PSM/RMP requirement is fundamentally flawed: Most places re-train each operator on EVERY SOP they are expected to perform at least every three … Continue reading
Posted in Compliance, Operator Training, System Optimization
Tagged Employee Involvement, EPA, Operator Training, OSHA, PSM, RMP, SOP, Standardization
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A debate on Management of Change
Recently a group of safety yahoos got together to discuss a situation: You have a freezer with racking. The racking needs to be removed for XXXX reason. You hire a contractor to do the job. You evaluate and train the … Continue reading
Posted in Contractors, General Information, Incidents, Management of Change, NEP, Standardization, System Optimization
Tagged Contractors, Incidents, OSHA, PSM, RMP, Standardization
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