Bryan Haywood

The CSB explains the non-typical BLEVE at the PES Refinery

  The rupture of the V-1 vessel appears to have caused a boiling liquid expanding vapor explosion (BLEVE, pronounced ‘blev-ē). A BLEVE is the “sudden loss of containment of a pressure-liquefied gas existing above its normal atmospheric boiling point at the moment of its failure, which results in rapidly expanding vapor and flashing liquid. The…...

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City of New Orleans Office of Inspector General (OIG) conducted a performance audit of the City of New Orleans’ (City) Department of Safety and Permits (S&P)

The City of New Orleans Office of Inspector General (OIG) conducted a performance audit of the City of New Orleans’ (City) Department of Safety andPermits (S&P). The objective of the audit was to determine if S&P inspectors (City inspectors) conducted their inspections in accordance with S&P policies and procedures. The scope of the audit was…...

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Rule Implementation Update: Chapter 296-71 WAC Refinery worker training and certification in high hazard facilities

Updated on 11/1/22   Effective Date: October 22, 2022 This rule created a new chapter, refinery worker training and certification in high-hazard facilities, implementing the advanced safety training requirements under chapter 49.80 RCW, adopted by the Washington State legislature in 2019. Chapter 49.80 RCW, requires owners of petroleum refining or petrochemical manufacturing facilities to use…...

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New York City DEP requires an RMP and some very specific additional requirements from U.S. EPA’s

New York City’s Community Right-to-Know Law (Local Law 92) requires facilities where extremely hazardous substances or regulated toxic substances are present at or above federally determined levels (Threshold Planning Quantity), to prepare and submit a Risk Management Plan to the Department of Environmental Protection on or before March first of every year. In situations where…...

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What are inherently safer practices?

We have recently heard the phrase “inherent safety” used by OSHA and EPA as both agencies work at revising/updating their process safety standards.  But what exactly is “inherent safety,” and why is it at the top of the Hierarchy of Controls for process safety? Inherently safer practices are an approach to designing safer chemical plants,…...

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WA-OSHA issues 46 serious and 17 general safety and health violations @ manufacturing facility/terminal ($192K)

A manufacturing company that works with dangerous chemicals faces $192,620 in fines for 46 serious and 17 general safety and health violations. The facility formulates products for agricultural fertilizer, airports, pulp and paper, and water treatment.  Washington State Department of Labor & Industries (L&I) inspectors found 13 violations relating to confined space entry rules due…...

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Hazardous Energy – visual display of PSI

If you have ever taught a LOTO course, you know that you will always get the questions… “Is ___ psi a hazardous energy source?”.  Regardless of the gas’s inherent hazard(s), we should always answer by saying “Zero = Zero,” and in LOTO, we are required to achieve a zero energy state.  So, any psi of…...

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CSB Releases Final Report into 2019 PES Fire and Explosion in Philadelphia

Pay close attention to the break in the smoke plumes on the right hand side of the screen… Today, the U.S. Chemical Safety and Hazard Investigation Board (CSB) released its final investigative report into a massive fire and explosions at the Philadelphia Energy Solutions (PES) Refinery in Philadelphia, Pennsylvania, that occurred in June 2019. The…...

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EPA issues RMP citations @ ice manufacturing facility (NH3 & $182K)

Respondent owns and operates an ice manufacturing facility that typically operates 24 hours a day, seven days a week. On June 26, 2019, EPA performed an inspection of the Facility pursuant to Section 112(r) of the CAA, Sections 304-312 of the Emergency Planning and Community Right-to-Know Act (“EPCRA”), and Section 103 of the Comprehensive Environmental…...

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Example of LATENT failures – Auditing

Many organizations have become very good at identifying the ACTIVE failures associated with an accident; however, in almost all of the accident investigations I have been involved with, I find LATENT failures to play a bigger role than active failures.  But that is a really hard pill for most organizations to swallow.  But there is…...

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Air France flight 447 Crash – Technical Failures led to Human Errors

As the trial involving the fatal crash of Air France Flight 447 begins today, prosecutors will argue that Air France (the airline flying the plane) and Airbus (the manufacturer of the plane) are liable for their role in the fatal 2009 crash. Both companies face charges of manslaughter and negligence in the incident that killed…...

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Butane Railcar(s) stored on a siding in NC found to be a stationary source under RMP

A North Carolina Administrative Law Judge found that railcars on a “siding” are a “stationary source,” as such, if they contain an EHS over the RMP threshold, they fall under EPA’s Risk Management Plan. This is in line with EPA’s recently proposed changes wanting to apply a 48-hour time frame to the term “storage, not…...

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