EWN Blog

 
January 23, 2015

Strategic Safety Programs

Organizations have changing needs, including safety needs. According to EHS Today, ΓÇ£the need for strategic change in safety is ambushing many organizations in today’s climate. Many organizations fail to realize in a timely manner that changing workforces require changing safety efforts.ΓÇ¥ Every year, specific employee dynamics change within an organization. New employees are hired. Seasoned employees choose retirement. As this process occurs, the commonly shared knowledge of safety procedures and expected safety behaviors can be lost or become ineffective in meeting the current needs of the ever-changing organizational dynamics. Overall workplace accidents can increase without a seemingly rational explanation. When increased accidents begin, the safety team or department become reactive and begin to search for solutions to solve the present problems. This can lead to a stream of spontaneous changes to correct unsafe conditions as they arise. However, a proactive and strategic safety program approach would evolve with the organization allowing for productive growth in the safest working environment possible. As we begin a new year and all other areas for strategic planning are being considered, a strategic safety plan can be developed outlining the organizationΓÇÖs goal definition of successful safety conditions. Revisit the current safety program and assess the […]
November 21, 2014

PHMSA Penalties Effect on Pipeline Incidents

In April of 2014, PHMSA released a statement summarizing the impact of strict enforcement on pipeline safety compliance for 2013. PHMSA ΓÇ£proposed more than $9.7 million in civil penalties against pipeline operators who violated safety regulationsΓÇ¥ ΓÇô the highest yearly amount since the inception of the agency. From these proposed civil penalties, PHMSA initiated 266 enforcement cases in the areas of: integrity management programs risk assessments failure prevention programs mitigation programs other regulatory violations identified during failure investigations and routine inspections PHMSA has chosen to pursue a reduction of safety violations through tougher enforcement. Tougher enforcements have led to a traceable and proven reduction in pipeline incidents and thereby an increase in pipeline safety. ΓÇ£Since 2009, PHMSA has proposed more than $33 million in civil penalties against pipeline operatorsΓǪΓÇ¥ and reported a 45% reduction in serious pipeline incidents. Serious pipeline incidents, by PHMSA definition, are ΓÇ£those resulting in fatalities or major injuriesΓÇ¥. With such impressive results, PHMSA will continue on the path of tougher enforcement. As recently as September 2013, PHMSA adopted new maximum penalties for pipeline operators in violation of safety regulations. The new maximum penalties are a result of the Pipeline Safety, Regulatory Certainty, and Job Creation Act […]
November 21, 2014

PHMSA 9 Protocols: Form 14 (Numbers 17 & 19)

Welcome back to our overview of the PHMSA 9 Protocols/Form 14- 22 Elements. As we have mentioned in our last few articles, PHMSAΓÇÖs 9 Inspection Protocols historically were listed 1-9 with each having several sub-parts. In August of 2013, PHMSA split the nine protocols into individual sub-elements. These are now listed numerically on PHMSAΓÇÖs Form 14. In this issue, we will look at numbers 17 and 19, which cover Personnel Performance Monitoring and Program Performance and Improvement. 17. Personnel Performance Monitoring Does the program include provisions to evaluate an individual if there is reason to believe the individual is no longer qualified to perform a covered task based on: covered task performance by an individual contributed to an incident or accident; other factors affecting the performance of covered tasks? 192.805(d) (192.805(e)) 192.805(d) and 192.805(e) (d) Evaluate an individual if the operator has reason to believe that the individual’s performance of a covered task contributed to an incident as defined in Part 191;(e) Evaluate an individual if the operator has reason to believe that the individual is no longer qualified to perform a covered task. If there is an incident or accident on a jobsite, any individual who is involved or […]
October 2, 2014

PHMSA 9 Protocols: Form 14 – 22 Elements (Protocols 10,11 & 12)

Welcome back to our overview of the PHMSA 9 Protocols/Form 14- 22 Elements. As we mentioned in our last few articles, PHMSAΓÇÖs 9 Inspection Protocols historically were listed 1-9 with each having several sub-parts. In August of 2013, PHMSA split the nine protocols into individual sub-elements. These are now listed numerically on PHMSAΓÇÖs Form 14. In this issue, we will look at numbers 10, 11 and 12 which address the requirements for training and evaluating on Abnormal Operating Conditions (AOCs) and recordkeeping. 10. Abnormal Operating Conditions (detail) Does the process require: 1) individuals performing covered tasks be qualified to recognize and react to abnormal operating conditions (AOCs), 2) evaluation and qualification of individuals for their capability to recognize and react to AOCs, 3) AOCs identified as those that the individual may reasonably anticipate and appropriately react to during the performance of the covered task, and 4) established provisions for communicating AOCs for the purpose of qualifying individuals? (TQ.OQ.ABNORMAL.P) (detail) 192.803 192.803 defines an Abnormal operating conditionas a condition identified by the operator that may indicate a malfunction of a component or deviation from normal operations that may: (a) Indicate a condition exceeding design limits (b) Result in a hazard(s) to […]
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