Bryan Haywood

[My] Weekly Safety Thought – Give the traditional SMS a chance

I am never disappointed in social media’s ability to tell me daily just how bad traditional safety practices are. I am also wondering if there is an aspect of business management that gets beat up and denounced more than safety. It seems we are never without so many new options/directions in safety, and unfortunately, many…...

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Defining and Quantifying the term “Remote”

In process safety circles, the word “remote” is found in several codes/standards. In OSHA’s Process Safety Management standard, we find it used in the Normally Unoccupied and Remote Facility (NURF) exemption (1910.119(a)(2)(iii). OSHA did us a favor by officially defining this phrase; however, they have never QUANTIFIED it. Normally unoccupied remote facility means a facility…...

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EPA issues RMP & EPCRA citations @ food facility (NH3 & $229K w/ $179K SEP)

Respondent owns and operates a cheese manufacturing facility. On March 22, 2022, EPA performed an inspection of the Facility to evaluate compliance with CERCLA Section 103, EPCRA Sections 304-312, and CAA Section 112(r). Based upon the information gathered during the Inspection and subsequent investigation, EPA determined that Respondent violated certain provisions of CERCLA, EPCRA, and…...

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It happened again… coworker turns on machine that a worker was “trouble-shooting”

On August 23, 2023, an employee was troubleshooting an unscrambler machine malfunction. The employee walked around to the bottom of the support frame of the machine, near two parallel drive chains. A coworker restarted the machine, and the employee was pulled into the machine by the drive chains. The employee was killed. Source: https://www.osha.gov/ords/imis/establishment.inspection_detail?id=1693870.015… Membership...

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Reporting, Investigation, Causal Analysis, Corrective Actions, and Tracking Process

This “process” must be in place within any SMS Incident Management Element, including a Process Safety Management System.  This process is used for ALL UNPLANNED events, not just EHS-related events.  Although this process appears simple, it can be full of challenges and very error-prone, eroding trust and credibility. There can be variations in each step…...

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Line Break gone bad (Flammable gasoline/hydrocarbons)

On May 23, 2023, @ 9:00 a.m. Employee #1 and Employee #2, both maintenance workers for a petroleum refinery, were troubleshooting an automated valve in the “Prime G Unit.” Flammable gasoline/hydrocarbons in the piping and flange portion of the automated valve were released, causing an explosion, and fire…. Membership Required You must be a member...

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OSHA issues PSM citations @ paint manufacturing plant (Flammable/Reactives & $290K)

OSHA issued $290,358 in proposed penalties following an August 2023 explosion at a paint factory in Garland, TX. One employee was injured in the explosion at the factory. OSHA issued one repeat and eight serious citations. The repeat citation was a $161,310 proposed penalty. The proposed penalties for the eight other citations are $16,131 each…....

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Pulling back the curtain on WHY workers fail to comply with “Cardinal Rules”

I want to thank Marcin Nazaruk for sharing this report with his LinkedIn connections.  The document below is a MUST READ and DIGEST for all safety professionals, but certainly for those who manage high-risk workplaces.  Equinor – the Norwegian Oil and Gas Company, with associated companies such as ConocoPhillips, Vår, or Aker BP, as part…...

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Safety Thought of the Week (Todd Conklin)

When a person responds as if the worker has become stupid, that response is more about the organization than the worker in question We must battle the need to believe that when a worker has some type of bad outcome, that adverse outcome happened because the worker became momentarily incompetent. Our thinking is driven by…...

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Safety Thought of the Week (Todd Conklin)

When a person responds as if the worker has become stupid, that response is more about the organization than the worker in question We must battle the need to believe that when a worker has some type of a bad outcome, that adverse outcome happened because the worker became momentarily incompetent. Our thinking is driven…...

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Defining and Quantify the terms “Adjacent and Near”

The word “adjacent” may be small in terms of letters used to spell it, but it has an enormous impact on the world of process safety.  Both OSHA’s Process Safety Standard (1910.119) and EPA’s Risk Management Plan (Part 68) use the word “adjacent.”  Here is how Webster defines “adjacent” adjacent (adjective): not distant: nearby It…...

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