Bryan Haywood

EPA RMP Citations @ manufacturing facility (Flammable Gases)

This case is significant as EPA used the International Fire Code as their basis for several General Duty Clause findings.  They also used NFPA standards in their inspection. Respondent owns and operates a facility that manufactures consumer and industrial products in liquid form and for pressurized containers that use aerosol propellants. Respondent’s manufacturing process uses

Unintentional errors vs. Intentional errors

Human error can be divided into either intentional or unintentional actions. INTENTIONAL actions—those actions that involve conscious choices. These actions are primarily due to judgment or motivational processes. UNINTENTIONAL actions—those in which the right intention or plan is incorrectly carried out or where there is a failure to carry out an action. These actions typically

Check writing and Human Factors

Before disciplining a worker for an “error” or “mistake” that led to undesired consequences, we need to ask ourselves one simple question… How often have we written 2022 when signing checks and documents this year? It is February 15th, 46 days into the new year, yet I just had to correct a document that I

Did OSHA miss the opportunity to improve safety around PRCSs?

In OSHA’s LOTO standard, they incorporated a requirement that required businesses to have forethought about the means used to isolate energy.  Specifically, the standard requires: 1910.147(c)(2)(iii) After January 2, 1990, whenever replacement or major repair, renovation or modification of a machine or equipment is performed, and whenever new machines or equipment are installed, energy isolating

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