Bryan Haywood

Taking the “Leap of Faith” from TRIR/DART into Leading Indicators

WOW, my article earlier this week on the flaws of the TRIR formula stirred a passionate debate among several SAFTENG members/clients/friends.  But from that debate, they now can see what their future safety metrics could look like.  I always get the following response (and it is a very legitimate response)… If measuring the TRIR and…...

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Total Recordable Injury Rate (TRIR) calculation flaw – Don’t drink the Koolaid!

As 2023 draws to an end, businesses across this great nation will be tallying their injury rates for bragging rights compared to other business locations, competitors, etc.  It is a 50+ year tradition for many of these businesses.  However, I wonder if this tradition would continue if they genuinely understood how flawed their calculation is. …...

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CPSC Proposes Rule to Establish Safety Standard for Residential Gas Furnaces and Boilers

On October 25, 2023, the U.S. Consumer Product Safety Commission (CPSC) published a proposed rule to establish a safety standard for residential gas furnaces and boilers. In the proposed rule, CPSC announces its preliminary determination that these products pose an unreasonable risk of injury and death. Therefore, CPSC’s proposed rule would require all residential gas…...

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Managing Risks from trichloroethylene (TCE)

In October 2023, EPA proposed to ban the manufacture (including import), processing, and distribution in commerce of TCE for all uses, with longer compliance timeframes and workplace controls (including an exposure limit) for some processing and industrial and commercial uses until the prohibitions come into effect. The rule would protect consumers, workers, occupational non-users and…...

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Types of Information Relevant for Response Planning

The Risk Management Program emergency response coordination activities require the owner and operator of a stationary source to provide to the local emergency planning and response organizations: the stationary source’s emergency response plan if one exists; emergency action plan; updated emergency contact information; and any other information that local emergency planning and response organizations identify…...

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Safety Thought of the Week… we need a sympathetic attitude towards people

If we wish to find out why accidents occurred and find ways of preventing them from happening again, we need a sympathetic attitude towards people who have committed so-called violations, have made slips, had lapses of attention, or not learnt what their training was supposed to teach them. It is a small price and is…...

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OSHRC discusses LOTO application on cord-and-plug equipment and the difference between “troubleshooting” and “cleaning”

NOTE:  I totally disagree with this ALJ decision; however, I give him much credit as I listened to the witnesses and followed the evidence he had presented.  This amputation injury was a LOTO violation in my eyes, and I would have argued this case differently.  But here are the facts presented to the Judge: what…...

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Management should make LOTO easy and efficient

In the year 2023, we still get the old questioning of the intent of LOTO.  It never fails; in our LOTO training, we will get operators repeating the application of LOTO to their jobs, word for word, as I have stated it, and then comes the $60,000 question… Does my boss know about this? Another…...

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Tote Tank Drain Nozzles Pose Leak Hazard (BSEE Safety Alert)

    Damage to Drain Nozzles on Tote Tanks Poses Leak Hazard BSEE has become aware of multiple instances in the Gulf of Mexico region where tote tank drain nozzles have been damaged, leading to leaks and spills during lifting events. These incidents have raised significant safety concerns, and it is crucial that possible risks…...

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[My] Safety Thought of the Week… safety auditing

If a facility spends hundreds of hours and thousands of dollars on paint the month before an audit… we may be doing “it” wrong! Early in my career, I sat in my weekly staff meeting when the plant manager announced our corporate safety and health audit. As in most organizations, these are “big deals”. A…...

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What, When, and Who… can you answer this for 100% of your process components

As we end 2023, we will have exceeded 30+ years of OSHA’s Process Safety Management (PSM) standard.  And yet, still today, we can walk out into a random covered process, place our hand on a process component, and the facility will struggle to provide us a “cut-sheet” for the component (i.e., what), when it was…...

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Be wary of your “leading indicators” being manipulated

In today’s safety arena, metrics still rage on.  I believe in metrics; everything should be DEFINED and QUANTIFIED in safety, and “performance metrics” are no different.  Advanced SMSs utilize “leading indicators” rather than “lagging indicators” such as injury rates, WC $s, etc.  This is a significant advancement in safety – measuring the activities (and their…...

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