Bryan Haywood

Fire extinguisher fails during pressure testing

What happened? The extinguisher, rated to 2900 psi was being tested to a pressure of 4351 psi. The incident occurred when the test pressure reached 2842 psi. The extinguisher was 13 years old. No one was harmed. The failure occurred under test conditions, and no personnel were nearby to be injured. The hydrostatic test was…...

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Equipment Opening gone bad (barium sulfide wash cone with a steam line)

NOTE: this was NOT a PSM covered process. OSHA determined the employee — on the job just two months — opened an air intake valve to inspect a noise coming from a barium sulfide wash cone with a steam line that was left open the day before. A rush of cold air in the steam…...

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Periodic Inspections should be SIMPLE and straightforward

Lockout is a life-critical program/process/procedure(s). Our efforts to VERIFY that the program/process/procedures meet our needs is a CRITICAL path in the LOTO process.  OSHA recognized this when it promulgated its Control of Hazardous Energy standard (1910.147).  Specifically, 1910.147(c)(6) “Periodic Inspections” requires the employer to verify the program/procedures and that the employees can properly apply them…...

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What does it mean when our facaility is a “High-hazard Group H occupancy”

High-hazard Group H occupancies are characterized by an unusually high degree of explosion, fire, or health hazard compared to typical commercial and industrial uses.  There is one common feature about Group H occupancies—they are designated as Group H based on excessive quantities of hazardous materials within the facility/building. Where the quantities of hazardous material stored…...

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Safety and Seperation Distances

From “facility siting” in a PHA to establishing emergency “assemble areas,” the methodology we use matters.  Many of us use a RAGAGEP from The European Industrial Gases Association (EIGA) titled Methodology for Determination of Safety and Separation Distances.  The “safety distance” is to provide a minimum separation that will mitigate the effect of any foreseeable…...

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CSB Releases Final Report into 2021 Fatal Vapor Explosion and Fire at Yenkin-Majestic Facility in Columbus, OH

Today the U.S. Chemical Safety and Hazard Investigation Board (CSB) released its final report on a flammable vapor explosion and fire at the Yenkin-Majestic facility in Columbus, OH, on April 8, 2021. One employee died during the incident, and eight other workers were injured. The CSB’s final report makes several important safety recommendations to Yenkin-Majestics,…...

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OSHA issues HAZLOC citations

Recently, OSHA cited a global manufacturer for HAZLOC violations using its 1910.307 – Hazardous (classified) locations standard.  We do not see this standard often cited, as in most PSM/RMP citations related to Hazardous Locations (HAZLOC), OSHA and EPA will reference the RAGAGEP NFPA 70.  It is one of our common findings in our PSM/RMP audits…...

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OSHA PSM citations @ chemical manufacturer (Diborane & $201K)

A global manufacturer of industrial gas could have prevented a May 2023 explosion that severely injured several employees by following required operating procedures in the manufacturing process where diborane — a toxic, colorless, and pyrophoric gas — is produced, distilled, mixed, and transferred. OSHA determined the explosion occurred as a 25-year-old product technician used a…...

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EPA issues RMP GDC & EPCRA citations @ facility (NH3 & $72K)

Respondent is an “owner or operator” of the Facility, which produced, used, or stored anhydrous ammonia, a hazardous substance. On April 25, 2019, the EPA conducted an inspection to determine compliance with the Comprehensive Environmental Response, Compensation and Liability Act (“CERCLA”) Section 103, 42 U.S.C. § 9603, and the Emergency Planning and Community Right-to-Know Act…...

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EPA issues RMP citations @ semiconductor manufacturing facility (HCL, SiH₄, NH3 & $10K w/ &19K SEP)

Respondent has a semiconductor manufacturing process at the Facility. The Facility has three covered processes using silane, ammonium hydroxide (conc 20% or greater), and anhydrous hydrogen chloride, meeting the definition of “process.” Respondent has greater than threshold quantities of anhydrous hydrogen chloride, silane, and ammonia (concentration 20% or greater) in covered processes at the Facility…....

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