Bryan Haywood

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 […]

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

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

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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