Bryan Haywood

Writen Operational, Maintenance, and Emergency Plan(s) for Industrial Hydrogen Piping (ASME B31.12)

As I dig deeper into ASME B31.12, Hydrogen Piping, I continue to find nuggets of best practices for HAZMAT piping.  ASME B31.12 requires each operating company having industrial piping, pipeline, and commercial and residential systems to have Operational, Maintenance, and Emergency Plan(s) that include the following:… Membership Required You must be a member to access...

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OSHA’s Heat exposure standard

On April 24, 2024, the department’s Occupational Safety and Health Administration presented the draft rule’s initial regulatory framework at a meeting of the Advisory Committee on Construction Safety and Health. The committee, which advises the agency on safety and health standards and policy matters, unanimously recommended OSHA move forward expeditiously on the Notice of Proposed…...

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ASME B31.12 – Leakage Survey

I have been working with several clients who are on a Hydrogen Fuel journey. It is fun to get deep into process safety protection schemes regarding NFPA 2 and ASME B31.12 and see the similarities and extra code requirements when dealing with large H2 gas systems. One of the interesting items regarding H2 piping is…...

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When does “storage incident to transportation” end?

Hazardous chemicals which are carried on transportation vehicles, including rail cars, can be subject to EPCRA reporting when they are not under active shipping papers and have reached the consignee identified on the shipping papers. See House Report No. 99-962 (Committee of Conference), October 3, 1986. 99 Cong. Conf. H. Report 962, at 311, which…...

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Arc Flash During Conductor Checks Causes First and Second Degree Burns

An experienced electrician checking conductors at an industrial facility unknowingly accessed an energized breaker bucket inside a substation and shorted phase to phase on the line side of the energized breaker switch at 347/600V. This resulted in an electrical shock, creating an arc flash. The worker suffered first and second-degree burns to their wrist, hand,…...

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EPA RMP citations @ repackaging facility (Cl2, SO2, Flammables & $261K)

Respondent is the facility’s owner and operator. The EPA inspected the Facility from July 27 to July 29, 2021, to determine the Respondent’s compliance with Section 112(r) of the CAAmand 40 C.F.R. Part 68 (“the Inspection”).  Operations at Respondent’s Facility include, among others, repackaging chlorine for utilization in sodium hypochlorite bleach manufacturing. The Facility also…...

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Pressure Testing piping with N2 turns fatal

At 8:04 a.m. on May 11, 2023, an employee working for an oil and gas support services company was found dead. On 5/10/23, the night before, the employee had instructed his coworkers from other contractors to go home, and he would finish the job. This was the last time anyone had spoken to the employee…...

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Fire Extinguisher inspection turns fatal

At 8:00 a.m. on May 8, 2014, an employee was inspecting fire extinguishers. The fire extinguisher discharged and struck the employee in the head, killing him. OSHA Case File    … Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Fire Extinguisher mainteance work turns fatal

On May 13, 2020, Employee #1 and Employee #2 were working to pressurize portable fire extinguishers. At some point, the extinguisher being worked on by the Employees exploded…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Fire Watch dies from burns

On October 16, 2023, Employee #1 worked for a construction gas & oil support contractor. Coworkers were cutting and welding an eye-lifting plate on a compressor skid. Miscellaneous petroleum products had been allowed to accumulate on, in, and around the compressor skid area, creating a fire hazard…. Membership Required You must be a member to...

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Is pressure and leak testing required after maintenance or alterations on piping systems?

It is good that we are finding fewer and fewer facilities without pressure testing and leak testing records on their process piping.  But now comes the difficult question: Is pressure and leak testing required after maintenance or alterations on piping systems? So, most companies will have their newly installed piping pressure tested and leak tested…...

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