Monthly Archives: August 2010

Anatomy of a Disaster – root cause analysis

On March 23, 2005, BP’s Texas City refinery had a major accident that killed 15 persons and injured 180. The U.S. Chemical Safety Board did an investigation and looked into the root causes of this accident.

Here is an excerpt from the Board’s video:


Note that the problems identified by the Board were not news to BP management. Internal audits and studies by BP had highlighted many of the same problems months before the accident.

This is a great lesson on what to do AFTER you have completed an internal audit. If management had paid attention to their own findings and acted on them, could this fatal accident have been avoided?

We discuss all these audit related issues at our 2-day seminars.

More on the Xcel saga

In my last post, I presented the U.S. Chemical Safety Board’s finding about one of the contributing factors that lead to the death of 5 contractors. Apparently, the Board was not very happy with the way Xcel conducted itself during the Board’s investigation. Here is a letter the Board sent to the CEO of Xcel expressing its displeasure.

The company actually went to federal court to try to block the release of the CSB report and its request was denied by the federal judge. The company is currently under criminal prosecution.

We have 2-day environmental regulations seminars scheduled in Florida (Fort Myers and Orlando), California (Santa Ana and San Francisco), Nevada (Las Vegas), Georgia (Atlanta), Texas (Houston), New Jersey (Newark) and Virginia (Virginia Beach). For our latest 2010/2011 environmental seminar schedule, click here.

Deadly accident waiting to happen…and it did

Many corporate purchasing departments have a policy of selecting the lowest bidder. That’s all fine if you are purchasing pencils and paper clips. But when it comes to safety related work, here are 5 deadly reasons why you should NOT always go with the lowest bidder when hiring outside contractors:


This video is an excerpt from the US Chemical Safety Board. Let’s learn from others’ fatal mistakes.

EPA’s Tailoring Rule on Greenhouse Gas

EPA issued its final rule on greenhouse gas (GHG) emissions on June 3, 2010. Under this rule, GHG will be regulated in two phases under the Clean Air Act.

Phase 1 will go from January 2, 2011 to June 30, 2011. If you are currently under a PSD permit (Prevention of Significant deterioration) and you emit more than 75,000 tpy of GHG, you will need to use Best Available Control Technology (BACT) to control you GHG emission.

Phase 2 goes into effect July 1, 2011 and ends on June 30, 2013. PSD permits will apply to new construction projects that emit more than 100,000 tpy of GHG. Modifications at existing facilities  that exceed 75,000 tpy of GHG will be subject to PSD requirements. Also if you emit more than 100,000 tpy of GHG, you will need to get a Title V permit!

Of course – this is America. So expect lawsuits to be filed against EPA on this final rule.

GHG is defined to include CO2, CH4, HFCs, PFCs, and SF6. For a complete set of the Tailoring Rule, click here. There is also a pretty interesting article in Pollution Engineering Magazine on this topic written by my fellow contributing editor Lynn Bergeson.

We have 2-day environmental regulations seminars scheduled in Florida (Fort Myers and Orlando), California (Santa Ana and San Francisco), Nevada (Las Vegas), Georgia (Atlanta), Texas (Houston), New Jersey (Newark) and Virginia (Virginia Beach). For our latest 2010/2011 environmental seminar schedule, click here.

Tips on writing audit reports

There are rules on how to write an audit report that is readable and can convey the message to the readers. Here are just a few of them:

  1. Use simple language. Do not use fancy words to impress the readers. Most readers are generally not impressed by big words. Always use familiar words. That does not mean you should not use long words. The word “instantaneously” is long but it is also familiar to most people. The word “alb” is short but it is not too familiar to many people.
  2. Get rid of deadwood. Here are some examples. Instead of saying “in the month of August”, just say “in August”. Instead of “a fine in the amount of $2000”, say “a $2000 fine”. Use “daily” instead of “on a daily basis”. Write as if you are being charged for every word – and not as if you are being paid for every word.
  3. Avoid accusatory words. Do not use these words: alarming, dishonest, perjured, intentional, negligent, willful misconduct, reckless, incompetent, fraudulent, dangerous, deplorable, criminal, etc.
  4. Write short sentences. Break up those long sentences into shorter ones. This makes it a lot easier for the readers.
  5. Stick to the facts. If you could not find a weekly inspection checklist, say so in your report. Don’t ay that the weekly inspection was never done. Just because you could not locate the checklist does not mean that the inspection was never done. The unavailability of the checklist may well be a separate finding.
  6. Be concise and precise. If you inspected 24 drums of hazardous wastes and 17 of them did not have “hazardous waste” labels on them, say so. Don’t say “many drum have no labels on them”. Say “17 out of 24 have no labels.”
  7. Avoid excessive use of acronyms. Don’t try to bedazzle your readers with your knowledge of technical terms and jargons. Keep in mind that many readers of your audit report are not engineers or scientists. Many senior managers are attorneys, accountants and MBAs. Acronyms such as PSD, RCRA, TRI, CERCLA, TSCA, RMP, PSM, etc will put them in a coma.
  8. Be specific in your conclusions. If you are doing a compliance audit and everything appears to be in order, the only thing you could possibly say is that “based on your review and visit on the day of the audit, the facility appears to be in compliance (on that day).”