Bryan Haywood

PHMSA issues guidance on NH3 Nurse Tank Non-Destructive Testing

In February 2024, the Federal Motor Carrier Safety Administration (FMCSA) and PHMSA issued a safety advisory to provide notice of the possibility of catastrophic failure of nurse tanks. This notice focused on nurse tanks manufactured from January 1, 2007, through December 31, 2011, by American Welding and Tank (AWT) at its Fremont, Ohio plant. Nurse…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

Preventing Hearing Loss Caused by Chemical Exposures (Ototoxicity)

Think about… when we are working around chemicals, we typically look at forms of exposure such as inhalation, absorption through the skin, etc., and we wear the appropriate PPE. For example, we may wear a full-face respirator, gloves, and an apron to protect against splash and vapors. But there is one organ that is normally…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

How detailed should our means to verify ZES be?

This is a pet peeve of mine: DETAILS MATTER in safety procedures and safe work practices. One thing we commonly find is some very generic language in LOTO procedures for how to verify each energy source has been isolated and is at a Zero Energy State (ZES). For example, you’re performing a “periodic inspection,” and…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

OSHA cites big rig parts distributor for confined space fatality (asphyxiation), safety hazards after worker fatality at the company’s Corpus Christi facility

OSHA has cited a big rig parts distributor for 16 serious safety violations after an investigation into a worker fatality found the company exposed workers to confined space and other safety hazards. OSHA initiated an inspection on Jan. 7, 2026, after an employee asphyxiated while inspecting a tanker trailer. OSHA cited the company for 16…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

The double H2S fatality event at a Kraft Mill is the classic anatomy of an accident – CSB Issues Woodland Pulp Investigation Update

This is WHY we need the CSB! We would never get this type of analysis from an OSHA investigation/report. No offense to my friends at OSHA, its just this type of analysis and passing on the critical information is not part of their charter. Today, the U.S. Chemical Safety and Hazard Investigation Board (CSB) released…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

Pressure testing piping and the connected vessels

Every once in a while, I come across a process design that leads to code issues down the road. This usually occurs with small pressure vessels (e.g., less than 5 cubic ft) that fall outside the scope of ASME Section VIII and also fall outside the scope of being a “confined space” (e.g., too small…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

Would the risk management program regulations cover the loading and unloading of transportation containers?

The definition of stationary source includes transportation containers used for storage not incident to transportation and transportation containers connected to equipment at a stationary source for loading or unloading (40 CFR Section 68.3). In a January 6, 1998 final rule (63  FR 640), EPA clarified that if a container remains attached to the motive power that…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

For CAA section 112(r)(1), General Duty, what are the chemicals that are covered?

There is no specific list of substances that subjects a stationary source owner or operator to the general duty provisions. The general duty provisions apply to owners and operators of all stationary sources that have any “extremely hazardous substances”. Extremely hazardous substances are NOT limited to the list of regulated substances listed under section 112(r),…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

Must separate amounts of regulated substances be aggregated for threshold determinations?

Drums containing regulated substances (listed in 40 CFR §68.130) are stored in several separate locations at a stationary source and there is no possibility that an accidental release in any of the individual storage areas would impact any of the other storage areas. Must the overall amount of the regulated substance present at the stationary…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

When your “life safety equipment” inspector is violating your HAZLOC requirements!

PLEASE ensure your “life safety” contractor inspector for Exits, Fire Extinguishers, EW/SSs, etc., is FULLY trained on the hazards of the area(s) they will be working in. This year, we have found two (2) national companies that provide these inspection services using electronic devices NOT rated for the hazardous areas where they are working. We…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

What say you… SCBA Bottles/Cylinders

We have 12 SCBA bottles/cylinders that were manufactured in 2003. These specific DOT bottles/cylinders came with a 15-year service life; meaning the service life expired in 2018. They were all Hydro’ed on schedule for their three (3) hydros in 2008, 2013, and 2018. KEY POINT: None of the bottles/cylinders have been used since 2018 (pointing

I asked AI to explain why Line Breaks are so hazardous

In an industrial and occupational safety context, a line break accident occurs when workers open pipes, valves, flanges, or vessels containing hazardous materials—such as toxic chemicals, flammable liquids, high-pressure gases, or high-temperature steam—and an unintended release occurs. Because these accidents can result in severe chemical burns, toxic inhalation, explosions, or physical trauma from pressure blasts,…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here
Scroll to Top