Bryan Haywood

What are the final changes in the Safer Communities by Chemical Accident Prevention (SCCAP) Rule?

/ Chemical Process Safety (PSM/RMP) /

Some of the more eye-opening revisions: Outlining STOP-WORK procedures in Program 3 employee participation plans A justification in the risk management plan is required when: hazard evaluation recommendations are NOT adopted facility-siting hazard recommendations are NOT adopted Safer Technology Alternatives Analysis (STAA) recommendations are NOT adopted third-party compliance audit recommendations are NOT adopted  A formal…...

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2024 DOT ERG is coming!

/ Emergency Response /

DOT/PHMSA have compiled the most important changes from ERG2020 to ERG2024, organized by the color of the corresponding section in the guidebook White Yellow/Blue Orange, and Green In addition to the changes listed below, all sections have undergone minor editorial changes for accuracy and consistency. In this edition, DOT/PHMSA has added QR codes to the back…...

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When are High-Vis garments no longer considered High-Vis?

/ OSHA Compliance /

NOTE: I have never managed a facility/workforce where we required Hi-Vis garments, except for Fire Watches and PRCS Entry Attendants, but those requirements were not for the user’s safety, so we did not get into all the ANSI requirements for these vests. However, I do equate this Hi-Vis effectiveness concern to what I dealt with…...

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Facility Siting – LPG Containers and Flammable Liquid Tanks (OSHA & NFPA)

/ Flammable Liquids /

This is another opportunity for facility sitting to apply specific metrics to the exercise. Just as the distances for Tank Truck and Rail Car Unloading/Loading facilities are intended to protect our bulk storage tanks, this is intended to prevent BLEVE(s) that could impact the above-ground storage tank. (emphasis by me) 1910.106(b)(2)(ii)(f) The MINIMUM SEPARATION between…...

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Facility Siting – Tank vehicle and tank car loading and unloading (OSHA & NFPA)

/ Flammable Liquids /

In some cases, we can actually put specific measurements in our “facility siting” analysis.  Take, for example, an old but often missed distance between the tank truck/railcar and the closest aboveground tank.  (emphasis by me) 1910.106(e)(4) Tank vehicle and tank car loading and unloading. 1910.106(e)(4)(i) Tank vehicle and tank car loading or unloading facilities shall…...

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Line Break gone bad (fluorocarbon)

/ Chemical Process Safety (PSM/RMP) /

At 7:30 p.m. on July 2, 2021, Employee #1, Employee #2, and Employee #3 performed two maintenance tasks in the M2 crude rectification section on the ground and second levels at tower M2-T250 and vessel V-207. On July 2, 2021, during the night shift, three (3) gas monomer chemical operators were exposed to toxic fluorocarbons…...

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Do OSHA citations change management’s behavior (ABC Model)?

/ Safety Management System /

We often refer to the ABC Model when discussing “Behavior Based Safety.”  ABC stands for Antecedent  ⇒ Behavior ⇒ Consequence An antecedent comes before a behavior and may trigger that behavior. A behavior is what/how the individual does an action. (good or bad). A consequence is something that follows the behavior (good or bad). So,…...

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EPA issues RMP citations @ commercial explosives plant (NH3 & Cl2 & $394K)

/ PSM and RMP Citations/Analysis /

The Facility uses, handles, and/or stores more than a threshold quantity of ammonia (anhydrous), ammonia (concentration 20% or greater), and chlorine, which are regulated substances, as specified at 40 C.F.R. §§ 68.115 and 68.130. The Facility’s Cooling Tower 2 chlorine injection area contains up to 4,000 lbs of chlorine in two (2) 1-ton cylinders, above…...

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Overfill of vapor recovery units (UK’s HSE Alert)

/ Chemical Process Safety (PSM/RMP) /

A Health and Safety Executive (HSE) investigation into a gasoline overfill of a carbon adsorption vapor recovery unit (VRU) revealed concerns with the VRU’s design. The overfill prevention system was NOT INDEPENDENT of the basic process control system (BPCS).  When the BPCS failed, the overfill prevention system also failed. This resulted in loss of containment,…...

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If we feel the need to discipline for a behavior, remember this…

/ Safety Management System /

We discipline for the behavior – NOT for the result/outcome of that behavior. This is never more true in safety-related events. When we discipline a worker for an injury for not wearing their PPE. We just set the standard for NOT WEARING PPE! So the next time a worker fails to wear their prescribed PPE,…...

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Helping others understand RISKS may be our biggest obstacle

/ Safety Management System /

I believe the most significant challenge we (safety professionals) face is those outside (and even some inside) our profession and their lack of understanding of RISKS. I am confident that any safety pro reading this has endured the old and tired argument… “We have been doing ________ that way for __________ years, and it has…...

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