Bryan Haywood

EPA RMP Citations @ food facility (NH3 & $130K)

At all times relevant to this CA/FO, Respondent operated a facility (the “Facility”) that utilizes anhydrous ammonia for cooling to pack, process, and distribute its food products. On July 11, 2024, EPA performed an inspection of the Facility to evaluate compliance with the Comprehensive Environmental Response, Compensation and Liability Act (“CERCLA”) Section 103, the Emergency…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

EPA RMP Citations @ food facility (NH3 & $106K)

At all times relevant to this CA/FO, Respondent operated a facility (the “Facility”) that utilizes anhydrous ammonia to manufacture and produce citrus products, to develop frozen fruit concentrate, juice, oils, and pulps from oranges, lemons, and grapefruits. On October 24, 2023, EPA performed an inspection of the Facility to evaluate compliance with the Comprehensive Environmental…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

What is the Welding Certification actually evaluating when the welding will be done by a pipe welding machine?

When we introduce a pipe welding machine (such as an orbital welder) into the fabrication process, the focus of the certification fundamentally shifts. Under industry codes such as ASME Section IX, the individual operating the equipment is no longer classified as a “Welder”; they are designated as a “Welding Operator.” Because the machine handles the…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

IFC 5001.3 Performance-based design alternative ERASES the MAQ Limitations

I am working with a client who is making every effort to comply with the Maximum Allowable Quantity (MAQ) limits for a flammable liquid process area. This process is a PSM-covered process, so I offered up how to work beyond the MAQ of 480 gallons for a fire control area. This compliance option 5001.3 was…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

Drip Pan Elbow on Steam System Relief Line

It is designed to collect and remove condensate while isolating the relief valve from the mechanical stresses of the discharge piping.  Here is a breakdown of its primary functions and operational mechanics:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

EPA updates its list of states/counties with RMP Enforcement Delegation

One state and two territories no longer implement the program, and the Regional office has taken over implementation for those three (3) areas. One (1) county in KY and three (3) counties in NC have been delegated enforcement authority. FL, ND, and MO have a partial delegation for either LPG or NH3. The current list…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

What are the maintenance requirements for Air Receivers and their PSVs?

I grew up in the process industries doing PSM/RMP; however, most of the air receivers at my plants were NOT associated with the PSM/RMP-covered process(es). And yet they were all in our MI program for routine inspections and testing of their PSVs. In fact, every pressure vessel in service on the plant site and its…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

OSHA updates VPP Policy and Procedures Manual

OSHA has made significant changes to Chapter 4, The VPP Safety and Health Management System. Chapter 4 now requires VPP participants’ SHMS to consist of the seven (7) core elements described in OSHA publication 3885, Recommended Practices for Safety and Health Programs, October 2016, and in OSHA publication 3886, Recommended Practices for Safety and Health…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

Why does the IFC 2024 Flammable Liquids Chapter (57) reference ASME B31.9 for leak testing rather than B31.3?

NOTE: If you’re in an INDUSTRIAL facility, especially one with a PSM/RMP-covered process, B31.9 is NOT your piping RAGAGEP! IFC 5703.6.3 dictates that piping for flammable and combustible liquids must be hydrostatically tested to 150% of the maximum anticipated pressure (or pneumatically tested to 110%). However, it offers a carve-out: “Unless tested in accordance with…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

Can anyone perform the “annual maintenance” on fire extinguishers?

I get some interesting questions and see some very strange things in my work around the country, but this one seems to have grown legs in the world of “cost-cutting” in safety. “Let’s have our maintenance people do the ‘annual maintenance’ on our fire extinguishers”… um NO WAY! And this is just not a “Haywood…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

ASME and PSM/RMP conflict on “records retention” needs

I will be fully upfront for those who wish to challenge me on this topic. YES, ASME B31.3 and 31.5 explicitly state that certain records that are required by the standard do NOT have to be “retained”. However, most people who challenge me on this topic fail to see that ittybitty two-letter word “if” in…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

Refinery fined £1 million after major gas leak

Structural collapse caused the release of around 2,400kg of highly flammable liquid petroleum gas.HSE investigation found that long-standing corrosion of the steel tower was not dealt with.Workers exposed to the risk of serious injury and burns in a major incident. The refinery has been fined £1 million after a major gas leak following an investigation…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here
Scroll to Top