Begins at 9:30 am - 11:00 am Meet under the pavillion
Join Blue Horizons Wellness, Schneider Risk Management, LLC (SRM), the City of Norton Shores, the Norton Shores Police Department on September 22, 2018 for a couple hours cleaning up the beach and the parking lot!
These groups are sponsoring the cleanups in conjunction with the Alliance for the Great Lakes. So please join all of us in keeping our local beaches clean and safe!!!
Did you think that once you “complete” your Risk Management Planning (RMP) and Process Safety Management (PSM) programs there is no more work to be done? Often, regulatory requirements are thought of as one and done. You prepare the document and its done, you don’t have to look at it again for five years. Not in this case.
These programs require vigilance, especially if the processes at your facility often change. For starters, both PSM and RMP include periodic actions that must be completed regularly. Here’s an abbreviated listing:
Both programs require documentation reviews, some documentation must be reviewed on an annual basis and others on a less frequent basis. For example, operating procedures must be reviewed annually. They must also be certified as having been reviewed.
Frequency of inspections and tests of process equipment must be done regularly in accordance with manufacturer’s RAGAGEPs. …. Raga-what? Recognized and Generally Accepted Good Engineering Practices. RAGAGEPs are based on established industry codes, standards, recommended practices, technical reports, or similar documents.
Compliance audits must be conducted every 3 years, and a process hazard analysis (PHA) must be conducted or revalidated at least every 5 years. A PHA may need to be conducted more often if there are changes to the process.
Process safety information must be updated whenever changes to the process occurs. This includes a range of information including P&IDs, materials safety data sheets, block flow diagrams, operating limits, material and energy balances, to name a few.
Emergency response information must also be updated regularly and training must be conducted annually for hazmat personnel and when job duties or procedures change for all other personnel.
RMP Submittals (or RMP eSubmit) may need to be updated more often than every five years if there are certain significant changes to your processes or regulated substances. For example adding a hazardous substances to an existing process above threshold quantities. Changes that trigger revisions to your PHA or off-site consequence analysis also require an update to your RMP eSubmit.
So, as you can see with this truncated list of periodic requirements, there is a lot to do after the main part of the program is established. I will say this, it gets a little easier as personnel understand what is expected of them and adopt a PSM/RMP safety culture.
One final thought. Remember to document all of your reviews and date all of your changes. The old saying still holds true. If it wasn’t documented and you can’t prove a review took place, it didn’t happen.
Every year in June the National Safety Council leads the nation in National Safety Month.This year’s theme is “No 1 Gets Hurt”.National Safety Month focuses on reducing leading causes of injuries and deaths at work, on the road and in our homes and communities.The NSC provides a lot of information on various safety topics. This year’s topics are:
Week 1: Emergency Preparedness
Week 2: Wellness
Week 3: Falls
Week 4: Driving
You can get downloadable materials that will help you create bulleting boards or conduct a safety briefing on these four topics.Materials include poster, tip sheets, articles, family activities, special offers, social graphics and more!Member materials include everything the public gets, plus checklists, 5-Minute Safety Talks, games, best practices and more! Get the safety materials here.
Once again SRM is attending and hosting a booth at the semi-annual Michigan Environmental Compliance Conference (MECC) located at the Lansing Center on June 12 and 13, 2018.There will be over 70 educational sessions, 38 exhibitors, and 18 DEQ program exhibitors.Click here for more information.
Come visit SRM at Booth 35. We hope to see you there!!
The receiving TSDF is responsible for submitting the e-Manifest information it receives to the U.S. EPA. It is also responsible for paying any e-Manifest processing fees due to the U.S. EPA following deployment. To ensure a smooth transition, generators are encouraged to review e-Manifest resources shared with them by their TSDF and to review resources on the MDEQ and USEPA websites.
Highlights for Generators
The e-Manifest launches nationwide on June 30, 2018.
Generators will have the option to create and submit manifests electronically in e-Manifest.
If generators would like to submit electronically, they must register for e-Manifest within the USEPA CDX online system.
Generators who wish to use electronic manifests will need an EPA Identification (ID) Number.
Generators may continue to use paper manifests after June 30, 2018; however, there is an extra charge for using paper manifests.
Existing 6-copy manifest form is being replaced with a new 5-copy form.
The system can also be used for shipments of Michigan liquid industrial by-products, but this is optional.
The eManifest online system is located in the USEPA CDX online system under RCRA Info and is currently available to explore. You will need to open a CDX account if you don’t already have one. There is a Youtube video from USEPA that walks you through a fictitious site and may be helpful.
To get more information, check out the MDEQ and USEPA resource pages, or contact SRM for assistance.
The OSHA PSM Standard (29 CFR 1910.119) is a “performance” standard rather than a “prescriptive” standard. In other words, the standard doesn’t tell you exactly what to do, such as when to collect a sample or log temperature. Rather, the PSM Standard requires you to achieve a certain level of performance. Then it is up to you to figure out how to maintain performance at that level. MIOSHA has adopted these regulations in GI Part 91 and OH Part 591.
The PSM Standards consist of 14 “Elements.” These “elements” are broad categories of compliance, like “Training” and “Employee Participation", each having its own set of requirements and goals that you set and then meet.
“14 elements!,” you sigh and think, “how am I going to get all of this work done when there is only one of me!” Let’s begin to answer with this – start with OSHA’s guide for small businesses entitled, Process Safety Management for Small Businesses. A copy can be found here.
In this guide OSHA identifies Process Safety Information (PSI), Process Hazards Analysis (PHA), Training, Mechanical Integrity (MI), and Compliance Audits as the elements most relevant to hazards associated with small businesses. Although all 14 elements will eventually need to be completed, this is a good place to start your PSM Program development. Why do you think OSHA started with these elements? Well, because by doing them you will be successful at making a good product and preventing your employees and neighbors from exposure to a highly hazardous chemical.
Process Safety Information (PSI) PSI includes a variety of information about your system, such as design and operating specifications for piping, vessels, valves and gauges. It includes drawings (P&IDs) showing the system layout, process flow and safety systems. This information will help your operators know when the system is operating in the sweet spot and when something is going wrong? The P&IDs will enable you to look up information about your system and see how its pieces and parts fit together and flow. Your maintenance team will be able to order and install the right equipment because they will know what design specifications they need for replacement parts. It is fairly straightforward. Your PSI and all the information about your system needs to be accurate and kept up to date because the rest of your PSM program is built around the PSI information.
Process Hazard Analysis Why do you need a PHA? Why can’t I just copy the PHA from the plant down the road that is really similar to mine? Because one size does not fit all. Even though some systems are considered “Off-the-shelf,” your equipment numbering system will likely be different and your system probably won’t have exactly the same configuration for piping, valves and safety equipment. Each system is different, so you cannot just copy another PHA and call it your own. Besides, your team has to go through the exercise. The PHA is a great learning and exploratory opportunity and a great tool for identifying weaknesses, even in the best systems. And, believe me, by the end of the PHA your team will discover weaknesses and things they didn’t know about before the exercise started.
Mechanical Integrity Effective preventative maintenance is one of the best ways to keep the highly hazard substance in your PSM regulated system and avoid deadly and costly accidents associated with worn valves, piping and gauges. This includes inspections of system components, exercising valves, ensuring gauges are working correctly and timely replacement of worn components. Training of the maintenance technicians keeps them safe and ensures replacements and repairs are done according to established codes and specifications.
Training Training is obvious, I think. Does a front desk receptionist need the same training as a maintenance technician? No. Staff and operations personnel need to be trained to the level of their involvement with the system. Everyone, at a minimum, needs to understand what their responsibilities are and what to do during normal operations and during emergencies. Office personnel need to know the dangers of the chemicals they are working near and what to do during an emergency.
Compliance Audits If the suggested elements in the small business guidance document supposedly have something to do with the information about the system, why are compliance audits included in this list? Probably because an audit is a good place to figure out where you are in the whole process of developing a PSM Program. Or if you happen to have a mature program, an audit is a good way to have a fresh set of eyes review the program to identify opportunities for improvement or to check if the documents describe the activities actually implemented at your facility. Remember the old industry adage, Plan Do Check? This is the check part.
Operating Procedures Another element I feel is important, but, is not in the OSHA guide as one of the five important elements mentioned earlier, is standard operating procedures (SOPs). This element, when done correctly, helps you make good product or refrigerate efficiently. If your procedures are wrong or ignored, it can result in employee injuries, equipment damage, raw material wastes and allot of wasted process time and money. On top of that, training of operators is critical, so they know how to keep the system in the sweet spot, how to recognize out-of-control conditions and then how to respond in a way that shuts the system down safely or brings it back under control. Oh, and they are a great training tool, too. So, you tell me if operating procedures are important or not.
It is a big job, but it doesn’t have to be overwhelming. By now you realize you alone cannot develop and implement a PSM program. It takes a team of operators, mechanics, engineers, their managers and of course, you, the compliance professional to get it all done.
SRM’s PSM professionals have been helping clients with their PSM programs for 20 years. We can evaluate your program, prioritize your opportunities for improvement and help you ensure your PSM program is effective and compliant. Just give us a call and we’ll show you how!
I had never seen the TV show This is Us before. I just happened to record it after the Super Bowl because I had heard it was good. Well, being a safety person I hit the jackpot. I don’t normally get choked up about TV characters, but this one hit close to home.
I was reminded of the fire escape plan I made with my kids years ago when they were young. I even remember sitting on the roof with my daughter outside her second-story bedroom window one evening so she would not be afraid of walking on the roof if she had to escape a fire. I remembered my insistence about changing the batteries in the smoke detectors, not just taking them out when they get low and start to chirp. Yes, I was a pain in the …. So, back to the show.
Both floors of the house are involved in what appeared to be a raging inferno. Then, Jack goes back into the house to retrieve the family dog. STOP!! OMG!! What were the writers thinking! When he came out the front door I cried “Foul!” to the writers and producers for allowing him to exit the house so unscathed, hardly even coughing. After all, the house was fully involved. If the smoke didn’t get him, the heat surely would have. Then, later it happened, Jack had cardiac arrest at the hospital.
At that point I felt somewhat gratified that the producers tried to make the show somewhat real, but in reality they should never have allowed Jack to exit the house except maybe as a smoldering heap. Because of the way it was done, it looked like it is possible to walk through a house fire like that and come out OK. For those of you that have been in a real fire, you understand the impact of the heat and smoke and how it burns the eyes and lungs and causes severe disorientation… Anyway, it is TV after all.
But you know what? I am actually grateful that the writers and producers killed off a main character because it started a conversation about smoke detectors and home fire safety. And, that made it all worth it! Rest in peace Jack. …. Oh, and don’t forget to change those smoke detector batteries!
There is a nice NFPA article on the This is Us TV show that can be found here.
A forklift operator was recently sentenced to 2 ½ years in prison for the forklift death of another contract worker at the Honda R&D Americas facility in Raymond, Ohio. The incident took place two years ago. When tragic incidents like this happen we need to ask what message should this verdict send to safety managers, supervisors and employers?
While we don’t have OSHA’s write-up, we can look at the facts as presented in the news story. The operator was known to drive through stop signs and drive forward when he had a load that blocked his view in front of the forklift. These two unsafe work practices are what lead to the accident. I would bet that everyone who has worked at a factory or warehouse for 2 years or more has seen this type of behavior at least once. And, that supervisors and managers know who the culprits are. The question is, what should companies do about this poor safety behavior? And, how long should the behavior be allowed to continue before effective intervention occurs?
Having been a safety manager, this story sent a chill up my spine. I hope it also sends a chill up the spine of every business owner, manager, supervisor and safety manager out there. Not because I enjoy seeing people sweat, but because too often I see companies on the surface claim “Safety First”, but behind the scenes they don’t always “walk the walk” by engaging their employees and contractors about safety and enforcing their own safe work practices.
Conversations about safety must occur regularly among hourly and management employees and contractors, training has to be up-to-date and relevant and safe work practices must be enforced consistently as part of every company’s culture. In this way, all employees are engaged in safety, and not just paying it lip service.
Research has shown us that employers who engage their employees and contractors about safety actually discourage poor behaviors and eliminate opportunities for preventable incidents like this one.
This is a chilling story and one that I hope never happens to any of our readers. But I also hope that it will serve as a reminder to everyone that if we as business managers let things go too far and don’t intervene, we can expect to see tragic incidents like this one happen again. I encourage everyone reading this article to download the news story and share it with supervisors and managers, and discuss the high personal loss for family and friends and the legal ramifications for individuals and the companies associated with the incident. And, ask the tough questions. How is our safety culture? Do we monitor effectively for unsafe work practices or unsafe conditions? How well do we interact with our contractors about safety? The local news story can be found here.