Bryan Haywood

Possible Catastrophic Failure of Nurse Tanks and Recommendation for Periodic Testing February 2024 (FMCSA Safety Advisory)

The Federal Motor Carrier Safety Administration (FMCSA) and the Pipeline and Hazardous Materials Safety Administration (PHMSA) issue this safety advisory to provide notice of the possibility of catastrophic failure of certain hazardous materials packages commonly known as “nurse tanks.” See Title 49, Code of Federal Regulations (49 CFR) §173.315(m). NOTE:  SAFTENG members can see pics…...

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PRCS fatality – Tanker Truck (oxygen-deficiency during cleaning)

For those who believe entering a PRCS would not happen when the Oxygen level is measured at 19.5% (IDLH for O2 Deficiency)… November 22, 2022, @ 1:00 p.m., an employee from a local chemical company was cleaning the inside of a tanker trailer. The employee was required to enter the tank and wash out the…...

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Your life saving safety tip… atmospheric hazards (1% = 10,000 ppm)

I am no longer surprised when I teach a PRCS or an Emergency Response course and the students who have been doing entries into PRCSs and responding to emergencies but are unaware of primary atmospheric conditions.  This is how I explain it… We have 100% volume of air in the space. That 100% volume is…...

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What does it mean to comply with 1910.147 vs. having a “management system” for Energy Control

Last month, I discussed what a “management system” would look like should we manage our Permit-Required Confined Space entry operations as a “management system” versus a standalone OSHA compliance program.  (CLICK HERE for that post) Today, I want to discuss the same approach but in respect to how we manage another life safety critical practice……...

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CHANGE… to improve safety (Administrative vs Engineering Controls)

A recent story in my local news was regarding changes to traffic patterns made to the 44th most dangerous intersection in OH.  A 2018 traffic study showed there had been 114 crashes at the intersection over the previous four (4) years; 40% of those resulted in an injury.  The state tried just about every administrative…...

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Does B31.3 require a percentage of welds to be x-rayed or some other means of testing?

Yes, ASME B31.3 requires volumetric testing (like x-ray) for piping welds, but the specific percentage of welds that must be examined is determined entirely by the “Fluid Service Category” designated by the system owner. Examination Percentages by Category… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in...

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Knowing the limitations of the respirator is CRITICAL

As is evident by several Permit-Required Confined Space incidents over the years, workers MUST FULLY understand the limitations of the respirators they are using.  This latest incident involved a worker who was vacuuming, and the nozzle became stuck inside the tank. To free the nozzle, the worker—wearing a respirator with organic filters used explicitly for…...

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Emergency Use Only SCBA and 90% Full

This week, I conducted a 24-hr HAZMAT Tech course for a client.  The facility had purchased some new SCBA cylinders, and we noticed an odd difference between two of the cylinders.  One cylinder was manufactured in 2021, and one was manufactured in early 2022, just six months apart.  As I was covering the requirements for…...

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Employer failed to address 3rd party OSH audit findings ($348K)

This is an interesting “press release” from OSHA.  Although OSHA has a “policy” not to use audits and inspections performed within the facility to issue citations against, when the employer does NOT address the hazards identified in the inspections and audits, OSHA can take issue with this failure to abate.  This is what seems to…...

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Is safety like bags of chips… half full of air?

Unfortunately, this economic image reminds me of some “safety programs” I have come across in my travels… The “program” looks great, sitting on the shelf in the fancy, shiny binder. But once we open the binder/package, we find a lot of “fluff” (i.e., air)! Let’s be serious… Safety is not a marketing or PR exercise…...

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Make safety data as coveted as financial data

Why is it that safety metrics always get such a bad wrap? We hear the voices from the back of the room… “what gets measured, gets manipulated,” so the outcry is that somehow measuring safety (other than the regulatory lagging indicators) is a waste of time and misleading. The funny thing is I never hear…...

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User Safety Notice SN122223 – 3M™ Scott™ Cylinder and Valve Assemblies

Immediate Action Required Impacted Dates:  October 3, 2023 – December 4 ,2023 3M™ Scott™ Cylinder and Valve Assemblies are safe to use once the instructions in this notice are carried out. 3M Scott have been made aware of a small number of cylinder valves that experienced noticeable rates of leakage upon initial inspection when the…...

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