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Workplace Safety and Health Law Blog

Posts in process safety management.

In our competitive environment, every manufacturer struggles to do more with less and to find capital for “nonproduction” areas, such as maintenance, safety, training, housekeeping and HR. If done in a shortsighted fashion, the employer learns through painful experience the sacred law of “unintended consequences.” Plant Engineering magazine (yes, a lawyer can read such stuff) ran a brief instructive story on harm to production and profits resulting from gradually shifting almost all maintenance functions to production employees. You’re probably thinking that “I wouldn’t do that,” but many employers have eliminated certain housekeeping workers and relied upon production employees to clean up their area or machine. One of the contributing factors to the deadly Imperial Sugar combustible dust explosion was accumulation of material in work areas … in part because operators were supposed to clean up after their shift, and did not do so.

Although OSHA's Process Safety Management (PSM) standard may be the most challenging of OSHA's regulations, the PSM standard, along with NFPA consensus standards about combustible dust have raised the importance of management of change (MOC) outside of refineries and chemical plants, and for the HR professional.

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