Bryan Haywood

OSHA’s position on Application of the HCS to Li-ion Battery Scenarios

When a manufacturer or importer ships defective/rejected Li-ion batteries for disposal or recycling, they are required to provide an HCS-compliant SDS to downstream employers. An HCS-compliant label would not be required for a product that is regulated under the CPSC.7 For example, consumer products that are generally regulated by the CPSC include button cells (e.g.,…...

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OSHA answers “Applicability of the HCS to Lithium Ion Batteries”

This [Portable] Rechargeable Battery Association (PRBA) inquiry includes a number of scenarios and questions raised by its members related to the article determination, hazard classification, consumer product exemptions, and labeling requirements The PRBA scenarios and questions have been paraphrased, followed by our responses. In addition, Attachment 1 to this letter provides several scenarios to give…...

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FM Global offers great advice on your Pre-Incident and Emergency Response Planning

Once again, I can not stress how valuable FM Global can be to your safety efforts.  Their Loss Prevention Data Sheets are FREE and some of the best guidance we can find.  Our profession is always complaining about spending money on ANSI, ASME, NFPA, etc. codes and standards. Yet, these Loss Prevention Data Sheets are…...

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Human Error is a Consequence, not a Cause

For most senior safety professionals, we have arrived at a place in our careers where we can understand the significance of what Dr. Reason said in 1997.  Although most would agree, we started our careers in a very different place when it comes to how we derived the root causes of accidents throughout our careers. …...

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Weekly thought on human errors

The significance (or severity) of an event depends upon the consequences suffered and not on the error that initiates it. The error that triggers a serious accident … and the error that is one of hundreds with no consequences… can be the same error.   Human Error, James Reason, Department of Psychology University of Manchester,…...

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Is this an Error, Mistake, or Violation? (Reason’s Human Failure Model)

Now keep in mind this is a child in the video.  But that does not mean adults would not do something similar after watching a co-worker successfully pull it off!  After all, MOST, if not all, unsafe acts are learned actions from co-workers.  So watch this short video, as painful as it may be to…...

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Things that make you go hmmmm (HFE 2023)

Your OSH or PSM/RMP audit report declares a human factor issue was found. You honestly wonder how much of a risk this really is, but you’re told it has to be fixed so we can close out the finding. So I present to you HF Engineering 2023… Membership Required You must be a member to...

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Maybe I’m just old school (SOPs/SWPs)

Maybe I’m just old school, but is it just too much to ask for: a well-written safety procedure, one that is written and analyzed with a safety pro and the worker(s) who do the actual work, that management will fully support the procedures everyday-everytime, including on holidays that fall on a Sunday, and employees will…...

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Human Errors are …

I thought I had shared this image before, but I could not find it. I did NOT create this image but have had it since 1994. It came from my first HF Engineering Course in preparation for Process Safety, specifically the HFA part of a PHA…. Membership Required You must be a member to access...

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Rail Car Incident Response for Crude, Ethanol & Other Flammable Liquids

April 8, 2023 — Quinnesec, Michigan The All Hazards Training Center at The University of Findlay has developed the Rail Car Incident Response for Crude, Ethanol, and Other Flammable Liquids training course for the U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration (DOT PHMSA) to educate emergency responders on freight rail car incidents…...

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Safety works from both angles!

A big mistake many make with Behavior Based Safety is focusing on people and their behaviors while the physical workplace goes to crap! We have to MANAGE BOTH to be successful! An old boss told me, “we have to take care of the house if we expect the kids to clean their rooms!” Claude Bloom…...

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Do you have a safety management system?

We often hear it: “We have a world-class safety management system.”  They are proud of what they have.  They have worked hard to get where they are.  But most of the time, they do NOT have a safety management system (SMS).  What they have is a safety “compliance manual.”  A binder that holds dozens of…...

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