Bryan Haywood

Line Break Gone Bad (Installing blinds to isolate a PRCS)

When we think the task is to improve safety for an entry, we may lose sight of the risks associated with opening process equipment, specifically flanges in the event. On July 23, 2009, Employee #1 and a coworker, both contract employees specializing in preparation of refinery equipment for entry, were installing blinds in piping preparatory…...

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Steam belongs in our Line Break Program

At 9:00 a.m. on October 6, 2019, an employee was attempting to open a flange. Steam released, burning the employee’s legs and lower body. The employee was hospitalized. 29 CFR 1910.269(d)(2)(iv)(D): The procedure did not clearly and specifically outline specific requirements for testing a machine or equipment to determine and verify the effectiveness of lockout…...

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Leak Testing per ASME Section V, Article 10 – Leak Testing

I see many contractors still attempting to argue that Pressure Testing and Leak Testing are the same tests. This is incorrect, as I have often discussed in my ramblings on this website. This post breaks down the requirements of the most common “leak test,” called the “bubble test.” ASME B31.3 refers us to ASME BPVC,…...

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Dawn dish soap may be great for dirty dishes and birds, but NOT for our “bubble test”

I see this often, a contractor wants to save some $ so they think they can make up their own “bubble-test” solutions. However, not only is this a very bad idea from a QA perspective, it is actually NOT TO CODE, as ASME Section V, MANDATORY APPENDIX I BUBBLE TEST — DIRECT PRESSURE TECHNIQUE, I-1032…...

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Safety Thought of the Week… People do not just become stupid

We must battle the need to believe that when a worker has some type of bad outcome, that adverse outcome happens because the worker becamemomentarily incompetent. Our thinking is driven by a bias toward bad things happening because someone did something bad. The bias that worker became stupid is really a strong force in how…...

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AMMONIA REFRIGERATION LIST OF KEY SAFETY MEASURES (Updated 1/25)

EPA developed the following key safety measures for the inspection of ammonia refrigeration systems and reviewed them with the International Institute of Ammonia Refrigeration. These are measures that EPA has determined should be in place, regardless of an ammonia refrigeration system’s age or size. This is not intended to be a complete list of important…...

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Human Factors – Valve Positions

I came across this arrangement, and we debated the position of this valve for 20 minutes, and 7 of us never came to an agreement. We even looked at other tanks that had this valve, and they were different. The valve shown below had its handle reversed as the tank’s ladder was in the way…...

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INERT GASES – Ventilation and/or Detection?

The 2024 IFC does a nice job of defining our options for work areas where compressed gases that are ASPHYXINATS are stored or used. A client wanted to use Argon, Nitrogen, and Helium in their Labs, and we were asked if this posed a hazard. We took the “inherently safe design” option first, which is…...

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NIOSH Science Policy Update – Fit-Testing HPDs

The following describes the NIOSH policy for determining the attenuation provided by hearing protection devices for individual workers. This statement updates the 1998 NIOSH Criteria for a Recommended Standard—Occupational Noise Exposure. RecommendationNIOSH recommends employers use individual, quantitative fit testing to evaluate the attenuation received by workers from their hearing protection devices. Quantitative fit testing is…...

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Occupational Exposure to Hazardous Chemicals in Laboratories (1910.1450)

The Standard entitled “Occupational Exposure to Hazardous Chemicals in Laboratories” (29 CFR 1910.1450; the “Standard”) applies to laboratories that use hazardous chemicals in accord with the Standard’s definitions for “laboratory use of hazardous chemicals” and “laboratory scale.” The Standard requires these laboratories to maintain worker exposures at or below the permissible exposure limits specified for…...

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OSHA recordkeeping when you have no recordables for the year

Question: If an employer has no recordable cases for the year, is an OSHA 300-A Annual Summary still required to be completed, certified, and posted? Answer: Yes. After the end of the year, employers must review the Log to verify its accuracy, summarize the 300 Log information on the 300A summary form, and certify the…...

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