Bryan Haywood

Emergency egress and Security Turnstiles

Many facilities have security requirements due to their handling, storage, and/or processing of certain hazardous materials.  These facilities will use perimeter security barriers such as fencing and personnel turnstiles.  And one of the top egress questions we get during audits is regarding the security turnstiles that are also part of the emergency egress path.  OSHA’s […]

Improving the means of egress illumination

If the means of egress bothers you, look no further than your state’s fire code for a beefed-up standard on egress.  OSHA standards are outdated and only intended to establish a “floor” that every employer has to work above.  Even OSHA will tell you that complying with their standards will NOT help a business achieve

EPA RMP Citations @ Chemical Manufacturing facility (Flammables and Toxics & $17K w/ $69K SEP)

Respondent is the owner and operator of a facility that produces olefins, ethylene oxide, propylene oxide, Methyl tertiary-butyl ether (MTBE), ethylene glycols, propylene glycols, ethanolamines, morpholine/Diglycolamine (DGA) surfactants. The facility is divided into nine process areas. The first area contains the propylene glycol unit G2. The second area contains the morpholine/DGA unit E7. The third

IBCs and their role in significant flammable liquid and environmental events

I have probably posted more than two dozen reports and videos showing the hazards associated with Intermediate Bulk Containers (IBC), almost all associated with flammable liquids.  In September 2019, a facility in Rouen, France, experienced a catastrophic event involving IBCs containing flammable liquids.  It was just a reminder of the hazards and level of risks

Why OSHA standards are NOT PSM RAGAGEPs (overfill protection)

We have discussed this before; there is a significant difference between Recognized and Generally Accepted Good Engineering Practices (RAGAGEPs) and OSHA’s minimum performance compliance standards.  OSHA standards may be adequate when quantities of the hazardous material(s) are managed at a lower inventory level; however, once those inventory levels exceed the PSM/RMP threshold, the old minimum

Process Venting to a “safe location” (Part II)

Last month I posted Exhaust Ventilation for Flammable Atmospheres and “Safe Locations” to explain the hazards of not controlling our flammable vapors associated with the required exhaust ventilation.  I received several comments and questions on that article regarding the normal process of venting hazardous materials and how to best define a “safe location” for these

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