Bryan Haywood

Kentucky’s Hazardous Liquid Unloading standard

A “Hazardous liquid” means, for the purpose of this regulation, a chemical or mixture of chemicals that is toxic, an irritant, corrosive, a strong oxidizer, a strong sensitizer,combustible, flammable, extremely flammable, dangerously reactive or pressure generating or which otherwise may cause substantial personal injury or substantial illness during, or as a direct result of any…...

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KY OSHA does not allow Tagout when the device can take a lock

I am not trying to start another LOTO fight about Lockout vs Tagout, but for those who do work in the state of KY, it is important to know that KY-OSHA does NOT allow an employer to utilize TAGOUT when the device can accept a lock.  This is different than what Federal OSHA allows.  Federal…...

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Visual Demo of “Work as Imagined” vs “Work as Done” (safety fencing modified)

Recently I was working with a client on some LOTO procedures, and I was out, and about in the plant, and as I was tracing down an airline, something caught my eye.  At first, I was not sure if I was just seeing things, as in my safety mind, there was just no way anyone…...

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Does a PSV have to be replaced after it lifts?

I grew up under the belief that when a PSV lifts, it gets replaced ASAP. However, this practice seems to have changed over the years. So lets see what our RAGAGEP says on the matter…… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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OSHA’s PSM and EPA’s RMP standards are a great start for a SMS – but need more than cut & paste

One of the things that EPA learned from OSHA’s roll-out of their PSM standard was that not everyone recognized the standard as a 14-element management system.  So when it came time for EPA to roll out its RMP, they made a “management system” part of its requirements.  However, EPA quickly disappointed when they said all…...

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PRCS entry “hoisting system” (1926.1203)

Recently we were performing an evaluation of a facility’s Confined Spaces and assessing if any were Permit-Required Confined Spaces and we came across this space.  I immediately knew that the winch was NOT intended for personnel and was installed for pulling the pumps in this lift station. However, my escort, the facility safety person (and…...

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PRCS Fatality – 12.1% Oxygen inside sanitation sewer

At 6:15 p.m. on August 19, 2022, two employees, 19 and 22, were digging a trench with an Excavator for a storm sewer line that was located in the center of a new multi-residential housing complex that was under construction. The trench was approximately 29 feet long by 16 feet wide and 7 feet 6…...

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PRCS Fatality – HAZ ATM inside tanker truck @ cleaning facility

At 1:00 p.m. on November 22, 2022, an employee, 48, was cleaning the inside of a tanker trailer from a local chemical company. The employee was required to enter the tank and wash out the tank with soap and water. Before entry, the oxygen level was 19.5% in the tank. The employee entered the tank…...

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Line Break gone bad (hydrogen cyanide)

At 3:00 a.m. on July 27, 2022, an employee was bolting a flow meter on a hydrogen cyanide (HCN) line that was dripping fluid with a coworker. The employee stepped away from the job after having difficulty installing the final bolts. The employee waved his hand in front of his face and backed away from…...

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OSHA issues LEP in seafood processing operations and related merchant wholesaler operations

This instruction establishes policies and strategies to be followed when scheduling and conducting programmed regional emphasis inspections of seafood processing operations and related merchant wholesaler operations in two targeted North American Industry Classification System codes (NAICS): 311710, 311711 and 311712 Seafood Product Preparation and Packaging, and 424460 Fish and Seafood Merchant Wholesalers These industries use…...

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World-Class Safety will always be “human based”

Yesterday, my post regarding the role of Artificial Intelligence (AI) stirred a lot of private comments among many of you. It was nice to see we can at least agree on our roles as safety pros and leaders. But I was reminded of a group discussion with many of those same safety pros years ago…...

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