Bryan Haywood

Pipeline Safety & Potential Impact Radius (PIR) Re-evaluations

/ Chemical Process Safety (PSM/RMP), Free, Hazardous Materials /

NTSB’s historical investigations into major gas and hazardous liquid pipeline ruptures continue to shape current rulemaking tracking. PHMSA has been actively reviewing the established Potential Impact Radius (PIR) calculation methodologies used in integrity management programs. The review aims to determine whether current mathematical models accurately account for human response data, rapid-ignition variables, and modern accident […]

FRC must be the outer layer – NYLON Hi-Vis vest are a problem

/ Chemical Process Safety (PSM/RMP), Emergency Response, Free, Hazardous Materials, OSHA Compliance /

In today’s workplaces, it’s hard to find a large business that does not require Hi-Vis Vest/Workwear. What is not hard to find is a business with HAZLOCs where workers are required to wear FRC but are wearing nylon Hi-Vis vests OVER their FRC. I am all for making workers more visible to powered industrial trucks

How often do SCBA cylinders need to be “topped off” to ensure they stay above 90% full?

/ Emergency Response, Free, OSHA Compliance, Respiratory Protection /

The amount of breathing air consumed during a monthly SCBA functional test (often referred to as the “monthly inspection” or “flow test”) varies slightly by manufacturer and the specific depth of your inspection/testing SOP. However, for a standard 30-minute/45-cubic-foot cylinder, you can estimate the usage based on the required NFPA 1852 checks.

When you see it… Flange Jumpers for Flammable Liquid & Combustible Dusts Piping

/ Chemical Process Safety (PSM/RMP), Flammable Liquids, Free, Hazardous Materials, OSHA Compliance /

Many may be familiar with “flange jumpers,” or some may call them “bonding jumpers,” that are used to ensure a continuity to ground across a flange with gaskets that act as “insulators”, such as PTFE gaskets. During a recent walkdown of a flammable liquids process, I came across this “jumper”. Design called for “jumpers” on

EPA RMP/EPCRA citations @ Refinery (HF & $270K)

/ Free, PSM and RMP Citations/Analysis /

Respondent operated a facility (the “Facility”) that refines petroleum products using a hydrofluoric acid alkylation process. On June 2-3, 2022, EPA performed an inspection of the Facility to evaluate compliance with the Comprehensive Environmental Response, Compensation and Liability Act (“CERCLA”) Section 103, EPCRA Sections 304-312, and CAA Section 112(r). Based upon the information gathered during

EPA RMP/EPCRA citations @ ethanol manufacturing facility (Flammables & $169K)

/ Free, PSM and RMP Citations/Analysis /

Respondent is the owner and operator of an ethanol manufacturing facility handling a mixture of hydrocarbon liquids, butane, isopentane, and pentane. Pursuant to 40 C.F.R. § 68.115(b)(2)(i), the entire weight of the mixture shall be treated as the regulated substance when the concentration of each of the regulated substances is 1% or greater by weight

EPA RMP/EPCRA citations @ food facility (NH3 & $262K)

/ Free, PSM and RMP Citations/Analysis /

Respondent operated a facility that utilizes anhydrous ammonia to provide cooling capabilities to package, refrigerate, store, and ship cherries and grapes.On September 16, 2021, EPA performed an inspection of the Facility to evaluate compliance with the Comprehensive Environmental Response, Compensation and Liability Act Section 103, EPCRA Sections 304-312, and CAA Section 112(r). Based upon the

Chemical hoses aren’t the only hoses needing annual inspection and pressure testing!

/ Chemical Process Safety (PSM/RMP), Emergency Response, Free, OSHA Compliance /

I have written over a dozen posts explaining the code requirements for annual inspection/testing of our chemical hoses. But in the world of PSM/RMP, there is another hose that requires annual inspection and testing… The primary standard requiring fire hose to be service-tested annually is NFPA 1962, Standard for the Care, Use, Inspection, Service Testing,

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