Bryan Haywood

CGA updates 2.1 – REQUIREMENTS FOR THE STORAGE AND HANDLING OF ANHYDROUS AMMONIA

One of my all time favorite RAGAGEPs is the Compressed Gas Association’s (CGA) 2.1 for those who handle anhydrous ammonia.  This year, they published the 7th Edition, and they made it even better.  Unlike so many RAGAGEPs, the CGA embraced the practice of “Continuous improvement” and really did a nice job with their additional explanations…...

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Light curtains disabled or not functioning (OSHRC)

This is a really good case to read.  It involves light-curtains and lasers as “guarding” and the fact that they were not functioning.  One of the machines had broken a manager’s foot when he/she entered to troubleshoot a problem (LOTO citation).  The facility had put tape on the floor as an indicator rather than fixing…...

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Inflatable plugs fail leading to Double Fatality PRCS accident

The men were helping to build a new sewage pumping facility. They were in a concrete foundation, a trench-like part of the structure about 40 feet deep. Sources said giant intakes five feet in diameter are inside the structure. Inflatable plugs secured with chains are used to keep the water out. Some sort of catastrophic…...

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Hazardous Location Electrical Markings – Material Groups (USCG)

This material is from the United States Coast Guard (USCG) and is an EXCELLENT explanation of the required electrical markings/labels on tools/equipment used within a Hazardous Location. Simply put, if the tool/equipment is NOT marked/labeled for use in the specific HAZLOC, it can NOT be brought into the HAZLOC…. Membership Required You must be a...

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FATAL Pressure Test (BSEE Alert)

On May 15, 2021, an incident resulted in the fatality of an offshore worker when two production personnel were pressure testing a 16-inch well surface casing and anexplosion occurred. The explosion entailed a high-pressure release with no signs of ignition.  Information obtained by BSEE during the subsequent investigation determined that personnel were using a high-pressure…...

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EPA issues RMP citations @ liquid natural gas pretreatment process (Flammable & $163K)

Respondent has a liquid natural gas pretreatment process at the Facility, meeting the definition of ” process” as defined by 40 C.F.R. § 68.3. Respondent receives natural gas by pipeline and pretreats the natural gas to remove carbon dioxide, sulfur compounds, water, mercury, and heavy hydrocarbons. The regulated substance under 40 C.F.R. Part 68 Chemical…...

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EPA issues RMP citations @ refinery (Flammable/Toxics & $385K)

Respondent is the owner and operator of an oil refinery. On September 9-13, 2019, the EPA inspected the Facility to determine compliance with 40 C.F.R. part 68. Based on the observations of the EPA inspectors at the inspection, the EPA has determined that Respondent uses, handles, and/or stores more than the threshold quantity of Flammable…...

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LOTO Periodic Inspections, HOP, and Psychological Safety

First, I am not fully bought into the “psychological safety” concept.  For me, it is just how we should manage safety, so I am not a “labels” kind of safety pro.  However, I get a lot of questions about HOP and Psychological Safety, and the one place we could begin to utilize these approaches is…...

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2024 safety resolutions… Written Program Specifics

On New Year’s Eve, I hope many safety pros will choose a 2024 resolution to end the regurgitation of OSHA standards as their “written programs.” I have always used the OSHA standard as my baseline, but these programs need to EXPLAIN HOW the facility will meet the requirements – not repeat the requirements. For example……...

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Safety Tip… its not the air that is the hazardous energy source; its what the air moves that creates the hazard

One thing that many find confusing regarding the control of hazardous energy is the actual hazard they are trying to render to a Zero Energy State (ZES).  This is a simple concept, but many get it wrong in their programs and machine-specific procedures.  Let’s take compressed air as an example.  Many compressed air systems in…...

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Fire extinguisher fails during pressure testing

What happened? The extinguisher, rated to 2900 psi was being tested to a pressure of 4351 psi. The incident occurred when the test pressure reached 2842 psi. The extinguisher was 13 years old. No one was harmed. The failure occurred under test conditions, and no personnel were nearby to be injured. The hydrostatic test was…...

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Equipment Opening gone bad (barium sulfide wash cone with a steam line)

NOTE: this was NOT a PSM covered process. OSHA determined the employee — on the job just two months — opened an air intake valve to inspect a noise coming from a barium sulfide wash cone with a steam line that was left open the day before. A rush of cold air in the steam…...

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