Bryan Haywood

EPA RMP Citations @ ingredients facility (EO and N(CH₃)₃ & Compliance Plan)

Respondent is the owner or operator of an ingredients facility with greater than 10,000 pounds of ethylene oxide in a covered process and greater than 10,000 pounds of trimethylamine in a covered process at the Facility. From the time Respondent first had onsite greater than 10,000 pounds of ethylene oxide and/or trimethylamine in a process,…...

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EPA RMP Citations @ chemical distribution facility (Formaldehyde & $125K)

The Respondent owns or operates a chemical distribution facility where the respondent has used or stored more than 15,000 pounds of formaldehyde. 40 C.F.R. § 68.25(a)(2)(i) requires the owner or operator of a stationary source to analyze and report in a Risk Management Plan (“RMP”) the worse-case release scenario that is estimated to create the…...

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PRCS Fatality (HAZ ATM); 1 entrant and 1 would be rescuer

On June 7, 2022, an employee working as an environmental engineer was replacing two failed pumps in a pump station. Two coworkers connected the new pumps to electricity, and the employee lowered the pumps into the vault. It was noted that the pumps weren’t working correctly, and water was pumped from the space. The employee…...

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Human Factors – Failed Checklists

Northwest Airlines Flight 255, a McDonnell Douglas MD-82, crashed in Romulus, Michigan, shortly after takeoff from Detroit Metropolitan Wayne County Airport on August 16, 1987, at about 8:46 p.m. It killed all six crew members and 148 passengers, and two people on the ground. There was only one survivor, it was a 4-year-old girl who sustained…...

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CFATS by the numbers on its 15th Anniversary

November 20, 2022 was the anniversary of Chemical Facility Anti-Terrorism Standards (CFATS) regulations.  And although it is not as well known as OSHA’s PSM and EPA’s RMP standards, it is a standard that many PSM/RMP practitioners deal with, so I thought it would be fitting to look at the CFATS numbers…… Membership Required You must...

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EPA offers insights into “Responding Facility” vs. “Non-Responding Facility”

In a recent training course, the EPA answered the “One Big Question”… (one that I have written about many times) Does the facility rely on emergency responders to stop the release of the regulated substance(s)? If the facility answers Yes, they are saying the local first responders will respond and stop the release.  This means…...

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Fish holds on commercial fishing vessels (H2S)

This Safety Alert addresses the importance of verifying atmospheric conditions in fish holds on commercial fishing vessels. There are specific hazards associated with the use of brine dip solutions, a common substance used in the industry. Brine dip combined with standing water can produce dangerous levels of hydrogen sulfide (H2S). The U.S. Coast Guard is…...

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Human Factors is Humans making decisions

Human Factors means HUMANS making decisions- OUR roles as safety professionals is to chart a path to SUCESS IN SAFETY, rather than hoping they avoid failure. Safety is NOT about luck. Safety is the confidence that there is a path to safety success – CULTURE is convincing the workers that the best path is the…...

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Human Factors 101… chartering a path for safe decisions

Human Factors mean HUMANS making decisions- OUR role as safety professionals is to chart a path to SUCESS IN SAFETY, rather than hoping they avoid failure. Safety is NOT about luck, safety is having the confidence that there is a path to success – CULTURE is convincing the workers that the best path is the…...

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EPA RMP Citations @ olefins facility (Flammables & $9K w/ $43K SEP)

Respondent is the owner and operator of an olefins facility which had two (2) incidents that occurred on December 20, 2021, and May 3, 2022, that resulted in accidental releases. Respondent has an olefins unit process at the Facility, meeting the definition of ” process”, as defined by 40 C.F.R. § 68.3. EPA Findings of…...

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Active vs. Latent Failures

A comparison of the characteristics of active and latent failures suggests that avoiding active failures tends to drive down the frequency of events while finding and rectifying the results of latent failures tends to drive down the severity of events…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member?...

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