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Don’t Miss Kestrel at the EHS Seminar in Galveston 6/5-6/8

June 1, 2017 - Kestrel Management

Join Kestrel at the 30th annual EHS Seminar next week to hear A.W. Armstrong  present on Using a Data-Driven Method of Accident Analysis: A Case Study of the Human Performance Reliability (HPR) Process.

EHS Seminar
June 5-8, 2017
Moody Gardens Convention Center
Galveston, Texas
Kestrel Presentation: Thursday June 8 at 8:30 a.m.
Kestrel Booth: #611

The Role of Human Error in Occupational Incidents

The concept of human error and its contribution to accidents and incidents has received considerable research attention in recent years. When an accident/incident occurs, investigation and analysis of the human error that led to the incident often reveals vulnerabilities in an organization’s management system.

This recent emphasis on human error has resulted in an expansion of knowledge related to human error and the most common factors contributing to incidents. Kestrel’s Human Performance Reliability (HPR) process helps to classify human error—with the additional step of associating the control(s) that failed to prevent the incident from occurring. This process allows organizations to identify how and where to focus resources to drive safety performance improvements.

In this presentation, A.W. describes Kestrel’s method for identifying the most frequent human errors and most problematic controls, and presents a case study wherein HPR was applied to a large petroleum refining company.

Catch Up with Kestrel

In addition to the presentation on June 8, Kestrel’s experts will also be available in the exhibit hall (booth #611) to discuss HPR, as well as our holistic approach to the management of process safety.

We welcome the opportunity to meet with you, learn more about your needs, and discuss how Kestrel helps our clients:

  • Improve occupational and process safety performance
  • Manage EHS and quality risks
  • Achieve regulatory compliance assurance

See you at booth #611 in Galveston!

Submitted by: A.W.  Armstrong

Now Hiring: Business Development Specialist

February 22, 2017 -

Kestrel is seeking a tech-savvy individual who can serve as the first point of contact in introducing our technology solutions to prospective customers looking to better manage their business needs and environmental, health, safety, and food safety compliance activities. The Business Development Specialist plays a key role in working directly with prospective clients to define their business needs and requirements, present Kestrel’s SharePoint approach, and develop identified clients into strategic accounts.

Read the full job description and apply.

Submitted by: Jesse Kunes

The New Age of Responsible Distribution Management

December 22, 2016 - Kestrel Management • dynaQ

The traditional hard copy binder of documents has long been the solution for managing Responsible Distribution requirements. However, recent technology innovations, such as Kestrel’s Code & Compliance Elite (CCE)™ software, have started to change the way NACD member companies manage their Responsible Distribution and other regulatory compliance obligations.

Webinar Presentation

In Kestrel’s recent webinar, we discussed how technology is changing the face of compliance. Our team provided a demo of CCE™ and attendees were able to hear directly from C.I. Thornburg about their experiences using CCE™ to meet NACD and other regulatory requirements. Watch the online recording now!

To schedule your live demo, contact Jesse Kunes today.

Submitted by: Jesse Kunes

Kestrel Expands Resources to Process Industries

October 31, 2016 -

ewan-ross-webKestrel pleased to announce the addition of Ewan Ross to Kestrel’s Texas operations. As a Senior Consultant, Ewan will be supporting Kestrel’s services in the process industries.

Ewan’s focus is on delivering sustainable results in process and personal safety, asset integrity, reliability, and risk management. He excels at strategic planning, identifying and building organizational capability, and shaping and implementing risk management processes and policies.

Ewan brings over 20 years of experience working with major oil and gas operators, including 12 years with Chevron, to the Kestrel team. Check out Ewan’s online bio to learn more about his experience and project highlights.

Submitted by: A.W. Armstrong

Top 10 Food Safety Building/Equipment Solutions

August 15, 2016 - Kestrel Food Safety

Every food supply company has an obligation to its customers to provide safe and quality food. In addition, a growing number of retailers and wholesalers require their producers and suppliers to implement compliance and certification programs. Food Safety Modernization Act (FSMA) compliance presents even a greater benefit to food-safe building and equipment programs, as it complements and aligns with previous GFSI-certified standard requirements (e.g., SQF, IFS, BRC, FSSC 22000) and demonstrates that a company is working actively to manage its food safety risks.

In today’s food safety-focused and competitive climate, it is challenging for companies to devote the resources required to maintain compliance activities at a sustained and satisfactory level—but it is essential.

The following solutions can help keep companies who work with food-related materials on track when it comes to managing food safety and certification requirements and achieving compliance under FSMA’s Preventive Control requirements.

  1. What are the issues that food and food industry sites must address to meet general plant control requirements for legal compliance and/or industry certification?

To comply with both regulatory requirements under FDA/FSMA and GFSI industry requirements, food companies must establish control of food safe premises, plants, and food risk zones. With recent changes, compliance is not limited to just companies that manufacture and distribute food product, but also to those that provide food chemicals, packaging, and logistics. The requirements apply to all companies distributing food or food ingredients to the U.S. market.

Food Plant Zoning

  • Signage
  • Locks and access controls
  • Pipe and utility marking
  • Floor and area marking and coding
  • Labels
  • PPI and PPE stations
  • Waste and water control
  • Color coding/tools/utensils/maps
  1. How do the regulatory and certification requirements for food safety impact controls for facilities and equipment?

The regulatory and certification requirements include elements to ensure all aspects of food safety. This includes “Food Safety and Security,” which requires the protection of food against the potential for deliberate or accidental contamination.  This is in addition to site and general security.

Equipment and Facility Controls

  • Locks
  • Lockout/Tagout systems
  • Seals and tags
  • Labels
  • Security gates/fences/areas
  • Closures/caps
  • Storage/containment
  • Emergency and response kits
  1. What are the food safety requirements for controlling food, non-food, and food contact materials?

A key focus for compliance includes the control of food and contact materials. This includes direct control, evidence of communication, and direction of employees to avoid the misuse or contamination/cross-contamination of food product. Control of utensils and tools used in the food processing areas represents a major area of inspection as part of the audit process.

Material Controls/Non-Food/Chemical

  • Locked and rated cabinets
  • Floor markings
  • Message boards
  • HMIS/NFPA programs
  • HazMat labels, inventory tags and forms
  1. How is food plant building maintenance addressed in food safety compliance?

The first requirement of a food industry plant is to ensure the proper building elements of construction and design. Once commissioned for food products or distribution, the facility must be maintained to its original level commissioned as fit for use.

Building Maintenance

  • Access and premise food maintenance
  • Exterior building envelope
  • Internal building envelope
  • Doors and locks
  • Process areas and critical maintenance (lubrication, PM, etc.)
  • Sanitary, employee areas, break rooms
  • Water, drains, and waste control
  1. What security requirements do food industry sites need to consider to meet regulations or GFSI industry certifications?

Food plants are included under the Department of Homeland Security (DHS) as requiring developed and implemented security programs. The registration of food plants under the FDA certification required by DHS is a key aspect of being approved and registered to operate for food sites.

Security (Food Safety and Security)

  • Premises security fences, gates, locks
  • Pass key and key control systems
  • Badges and badge readers
  • Video security and alarms
  • Building and equipment locks and access controls
  • Equipment and storage seals and programs
  • Security cabinets and storage
  • Tamper-evident seals
  • Signage – warning and informational
  1. How are hazard warnings dealt with in a food operation both to communicate with employees and visitors and to show evidence of compliance?

Compliance to food safety requirements provides that companies communicate with employees and visitors on the conditions for access to the food operation. To do so, it is expected that communication be established through various means to ensure notification of all related parties, including employees, visitors, truck drivers, service providers, contract employees, and contractors.

Hazard Warnings

  • Signage (building, equipment) – warning, hazard, directional, stop
  • GMPs
  • Labels and marking equipment and utilities
  • Floor markings
  • Conformities and allergens
  • Inspection and approval directions
  • Information boards
  • Location control
  1. How are warnings provided within a food plant for activities and people?

Compliance to food safety requirements provides that higher risk direction be maintained to ensure protection of food operations. This includes both documented and posted warnings to achieve communication at this level.

Directional Warnings

  • Premise directional signs
  • Food safety signage (GMPs, receipt, processing, release, shipping)
  • High risk equipment labeling, process warning signs and directions
  • PPE
  • Emergency response
  • Food safety mapping and locations
  • Employee sanitation
  • Employee rules
  • Employee hazard communication
  1. What requirements do food operations need to maintain to ensure the understanding of food safety throughout the organization?

Food safety requirements provide that management must ensure that food safety compliance is established throughout the organization and related parties. This can be accomplished through various means, including postings, signage, marking, mapping to enhance traditional methods of training, and meetings.


  • Visual workplace
  • Charting
  • Information boards
  • Employee communication
  • Hazard communication
  • Food plant zoning
  • Mapping
  • Directional location information
  • Preventive controls
  • Process requirements
  1. What specific controls are necessary for safe food operation based on identification of key infrastructure elements of a food operation?

Food operations are expected to maintain up-to-date engineering information, drawings and schematics, and related identification. This requirement is to ensure that all aspects of commissioning for food operation are maintained, with the assurance that physical identification and inspection of all related areas and fixtures is also demonstrated and maintained. Specific marking, labeling, identification, storage locations, tagging, and seals provide a means of meeting these requirements.


  • Truck and transport container tagging and sealing
  • Pipe and utility marking (engineering and pluming drawings)
  • Shadow boards/tool and parts storage
  • Identification and warning labels
  • Process equipment identification
  • Key program tagging (pest control, waste, etc.)
  • Service ID tagging (inspections)
  • PM tagging for food compliance (critical equipment)
  1. What provisions are there for asset management within a food operation?

Food safety regulations and standards require that all assets determined to be critical or to be maintained to achieve food safety be managed and maintained. To accomplish this program, means of achieving control over these assets must be developed, implemented, maintained, and evident.

Asset Management

  • Critical equipment management
  • Building maintenance management
  • Project equipment and building materials management
  • Asset inventory and verification management
  • Active versus inactive assets (in-service, out-of-service management)
  • Asset disposal management
  • Inventory status management – available, on-hold, disposition
  • Storage location management

Submitted by: Bill Bremer

Concerns over the Cost of Oil

July 28, 2015 - Kestrel Management

Recently, Kestrel Management sat in on the webinar 85 Dollar Oil (per barrel) by End of Year presented by Rick Bobigan, adjunct professor at the University of Texas – Austin. The webinar addressed a few key questions—questions that we know are top-of-mind for our oil & gas and chemical clients:

  • Why did the price of crude fall and why is it still declining?
  • Where is the bottom?
  • Will prices return to the $85-90 range and, if so, when?

Why did the price of crude fall?

In a nutshell, Bobigan explains that the price of oil has dipped due to a few key factors:

  1. S. dollar – The strength of the dollar has increased relative to other currencies (a dollar, therefore, buys more goods).
  2. Supply risk concerns – Buyers see the downward pricing trend and wait to purchase the good until it hits its lowest value, causing supply to exceed demand.
  3. Changes in supply and demand – A recent OPEC meeting discussed the oversupply of oil in the market from horizontal wells and oil shale compared to the consistent 1-2% annual increase in demand.

In the CNBC article Never mind Iran. Oil price is going nowhere (July 14, 2015), Signal Analytics CEO Stephen Davis also emphasizes the role of the global economy in driving the price of oil. A Reuters poll of 25 oil analysts forecast Iran could raise crude oil output by up to 750,000 barrels per day (bpd) by mid-2016; the global crude market already has a 2.6 million bpd surplus.

Davis goes on to state, “It’s not just that supply is moving up way more than it should, but it’s that demand is potentially weaker than people think, so it’s actually the worst of both worlds” when it comes to the dropping price of crude.

According to Signal’s analysis, demand from China has an almost 50% correlation to the price of oil—and China’s economic growth is forecast to be the weakest since the global financial crisis of 2008-2009 (CNBC, 2015).

Will prices return?

Oil prices fluctuate due to changes in supply and demand, currency valuations, supply risk, and the global economy. The amplitude of the price cycle depends on strength/weakness of these factors in relation to one another.

Bobigan believes that the return of oil prices will depend, first, on a weakening U.S. dollar. Once buyers see that price is increasing, many will act decisively to stock up and create a mini-shortage (i.e., greater demand). The premise for this recovery is that the cycle will mirror the 2007-2009 price cycle and that equilibrium will eventually be established at a higher price.

In addition, the supply of oil shale will diminish, and Bobigan believes that will also contribute to a rebound in oil prices. Oil shale is a more expensive method of crude extraction and, therefore, isn’t worth pursuing when the crude price is so low. Once this supply is removed, demand will begin to exceed supply and drive prices up.

As for the future of the global economy, that is still a somewhat unknown variable that will continue to impact oil prices, for better or worse.

 Submitted by: Will Brokaw

Using Data Analysis to Support Complex Business Decisions

April 22, 2015 - Kestrel Management

Today’s business managers face greater complexities than ever when it comes to making business decisions. For every business decision, there are a number of factors that impact the associated risks. Fortunately, the use of statistics, predictive analytics, and data mining has become increasingly useful in taking the “gut feel” out of making important and often complex business decisions.

Data-Driven Decisions

Most people are familiar with common descriptive statistical techniques, like measures of central tendency (e.g., mean, median, mode) or variability (e.g., interquartile range, standard deviation). More advanced data mining and predictive analytical techniques are increasingly being used to explore and investigate past performance to gain insight for future business decision making.

Data mining draws on large amounts of data to identify patterns, which are often classified as opportunities or risks. Predictive analytics encompasses a variety of statistical techniques that are used to analyze historical data to predict the most probable future events. A few examples of these include the following:

  • Discriminant Analysis – a machine learning model where a computer program “learns” a pre-existing data set that includes attributes and outcomes for each individual, and then predicts probable outcomes for individuals in the new data set based on attributes.
  • Linear Regression – creates an equation so that one variable can be predicted based on the known values of other variables.
  • Logistic Regression – a machine learning model where a computer program “learns” a pre-existing data set that includes attributes and a binary (“yes/no”) outcome for each individual, then predicts “yes/no” outcome for each individual in a new data set, along with a probability associated with the decision.
  • Decision trees – machine learning model where a computer program “learns” a pre-existing data set that includes attributes and outcomes (not necessarily binary) for each individual, then predicts outcomes for each individual in a new data set, along with confidence in the decision; also identifies the attributes that are most helpful for making predictions (i.e., those that are best able to discriminate between outcomes).
  • Neural networks – similar to decision tree, but more effective if finding the connections between attributes is a concern.

Together, this information can help decision makers to predict the outcome(s) of a decision before it is made—and make smarter decisions based on data instead of gut feelings. The following case studies demonstrate the value that statistics provide when it comes to making important business decisions.

Case Study: Wildfire Risk Index

For a large transportation organization, wildfires have historically presented a unique challenge. The company has worked diligently over the past several years to control its fire risk through research and a number of assessments. To help further minimize the wildfire risk, the company turned to past data and is working with Kestrel to develop a comprehensive Wildfire Risk Index to:

  1. Quantify the operational risks of wildfires (i.e., identify environmental conditions, determine areas of concern)
  2. Make informed business decisions to help minimize identified risks

Creating the Index requires a significant amount of data from both internal and external resources, including traffic, weather, geography, internal fire incidents, and others. This information is used in several components contained within two main models that create the Wildfire Risk Index. These model components are relatively simple when used on their own. The complexity arises when combining the various models and their components into a single Wildfire Risk Index that reasonably reflects relative risks, while considering all variables.

The ultimate output of the Wildfire Risk Index is a single number that quantifies the relative risk of wildfire by location and by month. This information will help the company to:

  1. Identify the areas of greatest risk.
  2. Focus resources on those areas.
  3. Make more informed decisions regarding operations—like when to plan hot work and when and where to perform vegetation control—to help prevent future incidents.

Case Study: Incident Data

For a large petroleum refining organization, safety and environmental incidents present a significant risk to operations. In order to reduce incident frequency, the company has implemented a robust safety management system, which includes frequent audits and inspections. Despite the company’s best efforts, however, incidents have continued to occur.

To further improve safety and environmental performance, Kestrel is working with the company to conduct detailed reviews of previous incidents using Kestrel’s proprietary Human Performance Reliability (HPR) approach. This approach identifies and classifies the human factors contributing to incidents, as well as the controls associated with those human factors (engineered, administrative, and/or PPE). Once the reviews are finished, the results are statistically analyzed to generate a prioritized list of human factors to be addressed. Kestrel’s Human Factors Integration Tool (HFIT™) software then generates a list of existing controls associated with the top human factors, as well as a list of missing controls that could be created and implemented.

The ultimate output of the incident review process is to help the company identify the human factors contributing to incidents, create or improve associated controls, manage operational risks, and protect the health and safety of workers and the surrounding environment.


These examples demonstrate how predictive analytics can be used to support decision making. The versatility of predictive analytics, combined with the variety of statistical techniques available, can be applied to help companies analyze a wide variety of problems and gain insight for future business decision making.

Submitted by: Will Brokaw

Kestrel Is Hiring!

March 9, 2015 -

Kestrel is seeking several professionals to join our team. Our staff is integrally involved on every project, offering perspective and interacting directly with our clients to reduce risks, verify compliance, and ensure business sustainability. We are looking for candidates who might be a good fit for our organization and our clients’ needs. We currently have the following positions available:

Submitted by: Chris Tarpey

Business Benefits of a Well-Documented Management System

August 4, 2014 - Kestrel Management

A management system is the framework that enables companies to achieve their operational and business objectives through a process of continuous improvement. In its simplest form, a management system implements the Plan, Do, Check, Act/Adjust cycle. Several choices are available for management systems (ISO is commonly applied), whether they are certified by third-party registrars and auditors, self-certified, or used as internal guidance and for potential certification readiness.

From Compliance Only to Compliance within a Management System

The connection between management systems and compliance is vital in avoiding recurring compliance issues and in reducing variation in compliance performance. In fact, reliable and effective regulatory compliance is commonly an outcome of consistent and reliable implementation of a management system.


10 Reasons to Implement at Management System

Beyond that, there are a number of business reasons for implementing a well-documented management system (environmental, safety, quality, food safety, other) and associated support methods and tools:

  1. Establishes a common documented framework to achieve more consistent implementation of compliance policies and processes—addressing the eight core functions of compliance:
  • Inventories
  • Permits and authorizations
  • Plans
  • Training
  • Practices in place
  • Monitoring and inspection
  • Records
  • Reporting
  1. Provides clear methods and processes to identify and prioritize risks, set and monitor goals, communicate those risks to employees and management, and allocate the resources to mitigate them.
  2. Shifts from a command-and-control, centrally driven function to one that depends heavily on teamwork and implementation of a common system, taking into consideration the necessary local differences and building better know-how at the facility level.
  3. Establishes a common language for periodic calls and meetings among managers, facility managers, and executives, which yields better goal-setting, priority ranking, and allocation of resources to the areas with greatest risk or the greatest opportunity to add business value.
  4. Empowers facilities to take responsibility for processes and compliance performance without waiting to be told “what” and “how”.
  5. Enables better collaboration and communication across a distributed company with many locations.
  6. Enables the selection and implementation of a robust information system capable of tracking and reporting on common activities and performance metrics across the company.
  7. Employs a design and implementation process that builds company know-how, captures/retains institutional knowledge, and enables ongoing improvement without having to continually reinvent the wheel.
  8. Creates consistent processes and procedures that support personnel changes (e.g., transfers, promotions, retirements) and training of new personnel without causing disruption or gaps.
  9. Allows for more consistent oversight and governance, yielding higher predictability and reliability.

 Submitted by: Tom Kunes

Join Kestrel at ChemEdge 2014 in Nashville

July 15, 2014 - Kestrel Management • dynaQ

It’s time for ChemEdge 2014! Kestrel Management will be attending and presenting again this year. We would enjoy the opportunity to connect with you in Nashville, discuss your EHS compliance management needs, and offer you a free 30-day trial of Kestrel’s software tool, Responsible Distribution powered by dynaQonlineTM. Visit our booth (#404) to learn more.

ChemEdge 2014
August 19-22, 2014
Omni Nashville
Booth #404

Kestrel Presentation
Tuesday, August 19, 1:00-2:00 p.m.
Driving Continual Improvement with Internal Auditing

Stop by our presentation, visit Kestrel at booth #404, and check out the current projects and EHS compliance management services we’re providing the chemical industry—plus the latest advancements in dynaQTM, our flexible assessment software.

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