Bryan Haywood

FATAL entry into LPG Storage Tank (O2 Deficiency)

August 18, 2022, at 3:00 p.m., an employee entered an empty liquid propane gas (LPG) tank for servicing at an industrial equipment wholesaler facility. Earlier in the day, the employee approached a supervisor and said he wanted to enter the tank to spray Torq CB III penetrating oil product on an internal valve to loosen…...

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Pressure Testing GONE BAD (Vessel Failure)

At 9:20 a.m. on July 12, 2023, an employee working as a supervisor was testing for leaks in a tank at a leak test station. Tanks are laid on their side for leak tests. The top of the tank faced the pressure test chamber, and the bottom faced the opposite direction. The employee began grinding…...

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Classic “error trap” – Trap Door Design

When you see it… Classic “error trap” – no pun intended but this is truly a “trap” door An “error trap” is defined as “a condition or circumstance that provides fertile ground for mistakes to happen.”… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Classic “error trap” – Bottle Top

When you see it… Classic “error trap” – Bottle cap An “error trap” is defined as “a condition or circumstance that provides fertile ground for mistakes to happen.”… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Classic “error trap” – EXIT Door (#2)

When you see it… Error Trap 101- Exit Door Confusion An “error trap” is defined as “a condition or circumstance that provides fertile ground for mistakes to happen.”… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Classic “error trap” – EXIT Door

When you see it… Error Trap 101- both get you out the door; one summons a “welcoming committee” soon after you exit! An “error trap” is defined as “a condition or circumstance that provides fertile ground for mistakes to happen.”… Membership Required You must be a member to access this content.View Membership LevelsAlready a member?...

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Classic “error trap” – damned if I do and damned if I don’t

When you see it… Classic “error trap” – damned if I do and damned if I don’t An “error trap” is defined as “a condition or circumstance that provides fertile ground for mistakes to happen.”… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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OSHA answers the question: Frequency of refresher training for first aid and CPR?

OSHA cancelled CPL 2-2.53 in 2007. Your letter cites OSHA’s current guidelines for CPR training contained in OSHA 3317-06N 2006, Best Practices Guide: Fundamentals of a Workplace First-Aid Program. Although OSHA does not mandate retraining intervals, this guidance, at p. 13, recommends that “Instructor-led retraining for life-threatening emergencies[,]” specifically CPR and AED, “should occur at…...

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OSHA clarifications for breathing air quality and use

The Suburban Manufacturing Group manufactures filtration and drying systems for compressed air. A part of the product line is a compressed air filtration system for use with supplied air respirators (SARs). You have asked for OSHA’s interpretation on addressing air quality and clarification on various designs or configurations of currently marketed breathing air systems. Please…...

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OSHA clarifies some PSM standard terms

Not only did OSHA update its Compliance Directive for Process Safety Management standard 1910.119, effective January 26, 2024, this week, they also posted a Letter of Interpretation (LOI) clarifying several key terms used in its PSM Standard.  Terms defined include: Employer Employee Access, as used in the EP element Accessible, as used in the SOP…...

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OSHA answers the question… Would it be compliant if an employer reviews a representative sample of the entry permits during the one-year review?

1910.146(d)(14) does not specify how many or what percentage of entry permits must be reviewed annually. Would it be compliant if an employer reviews a representative sample of the entry permits during the one-year review?   The easy answer is NO, ALL CANCELED ENTRY PERMITS AND NOT A REPRESENTATIVE SAMPLE OF THE ENTRY PERMITS must…...

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