Bryan Haywood

Go ahead, tell me I’m crazy… but an FRC uniform provider/laundering contractor is a PSM/RMP contractor

In 2023, I began taking issue with the condition of Flame Retardant Clothing (FRC) being used in REQUIRED areas and tasks.  We see garments that in no way would pass a “routine inspection” per NFPA limitations.  My go to RAGAGEP for this is NFPA 2113, Standard on Selection, Care, Use, and Maintenance of Flame-Resistant Garments

Overfill prevention system was not independent of the Basic Process Control System (BPCS) (UK’s HSE)

A Health and Safety Executive (HSE) investigation into a gasoline overfill of a carbon adsorption vapor recovery unit (VRU) revealed concerns with the design of the VRU. The overfill prevention system was NOT independent of the basic process control system (BPCS).  When the BPCS failed the overfill prevention system also failed. This resulted in loss

PSM/RMP Auditing in the 21st Century

OSHA’s PSM standard is over 30 years old, and EPA’s RMP standards/rule is approaching its 30th birthday fast.  They are so 20th century (LOL)!  This article is about how some of my clients are approaching their 3-year audits required by both standards.  This approach embraces the “audit element” of the process safety management system as

[Last] Safety Thought of the Week 2023

The value of a Root Cause Analysis and Corrective Action Plan process to a business If the critique process is effective and an organization successfully determines why the event occurred, the appropriate corrective action can be achieved. The avoided cost associated with recurrence and improvement in performance is the organization’s dividend.

EPA issues RMP & EPCRA citations @ facility (NH3, SO2, Cl2 & $69K w/ $109K SEP)

Respondent owns and operates a chemical warehouse and repackaging facility. From November 2 through November 5, 2021, EPA performed an inspection of the Facility to evaluate compliance with Section 103 of the Comprehensive Environmental Response, Compensation and Liability Act (“CERCLA”), EPCRA Sections 304-312, and CAA Section 112(r). Based upon the information gathered during the Inspection

OSHA’s proposed “Training” requirements in its new Emergency Response standard

Training is the backbone of WERTs and ESOs. Effective training produces team members and responders with the skills, knowledge, and confidence to safely perform their duties in the face of various hazards in emergency incidents. Paragraph (h) of the proposed rule contains requirements for INITIAL and FOLLOW-UP training for responders and team members and requirements

OSHA’s proposed “Medical and Physical Requirements” requirements in it’s new Emergency Response Standard

Emergency response is a physically demanding occupation; approximately half of all firefighter on-duty and line-of-duty deaths are due to cardiovascular events. Emergency response activities can place a tremendous strain on the cardiovascular system, which can trigger a catastrophic cardiovascular event. This is especially true for team members and responders with pre-existing heart conditions, which they

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