Bryan Haywood

Hearing Protection is the perfect example of why there is a Hierarchy of Controls

We see it just about every day; heck, we even see it with safety people… not properly rolling, lifting, inserting, and holding their hearing protection as they insert them.  But noise is a “chronic” hazard and thus far too many workplaces fail to respect it.  Unfortunately, in the vast majority of projects, we have completed…...

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Why being “Authorized” means something in LOTO

How did you spend your Friday night and Saturday?  Me?  I spent mine helping a client manage a traumatic injury to a new employee with less than 3-weeks on the job.  And like most employers, this company truly cares about their employees and honestly wants the best for their employees.  This business may be the…...

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Variable and Constant Errors (Dr. James Reason)

Although it may be possible to accept that errors are neither as numerous nor as varied as they might first appear, the idea of a predictable error is a much harder one to swallow. If errors were indeed predictable, we would surely take steps to avoid them. Yet they still occur. So what is a…...

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Error Probabilities (Reason Model)

Assigning probability values to errors is still very much an art form.  Nonetheless, there is sufficient general agreement about the likelihood of errors occurring in various generic tasks to put them into sensible rank order. Their main use is to provide benchmarks for the range of error probabilities over different jobs.Here is a list of…...

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The Three-Bucket Model for assessing risky situations (Reason)

When we were children, adults frequently told us to stop and think—good advice, but they rarely told us what to think about. I have sought to overcome this omission with the ‘three-bucket’ model described below. This model forms the basis of the mental skills designed to impart error wisdom and risk awareness.  The buckets correspond…...

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EPA’s Risk Management Program Safer Communities – Root Cause Analysis

EPA is proposing to require all facilities with Program 2 and 3 processes to conduct a root cause analysis as part of an incident investigation for an RMP-reportable accident as defined under 40 CFR 68.42. This includes requiring the root cause analysis to include specific elements, requiring the use of a recognized investigation method, and…...

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EPA’s Risk Management Program Safer Communities – Safer Technologies and Alternatives Analysis (STAA)

EPA is proposing a requirement in 40 CFR 68.67(c)(9) for some Program 3 regulated processes to consider and document the feasibility of applying safer technologies and alternatives as part of their PHA. This requirement applies to petroleum and coal products manufacturing processes (classified in NAICS code 324) and chemical manufacturing processes (NAICS code 325) that…...

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EPA’s Risk Management Program Safer Communities – Facility Siting

The location of stationary sources, and the location and configuration of regulated processes and equipment within a source, can significantly affect the severity of an accidental release. The location of the stationary source in relation to public and environmental receptors may exacerbate the impacts of an accidental release, such as blast overpressures or concentrations of…...

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EPA issues RMP citations @ frozen foods processing facility (NH3 & $100K)

Respondent is the owner and operator of a frozen foods processing facility that includes anhydrous ammonia storage tanks, valves, piping, compressors, freezer tunnels, and other buildings, structures, equipment, installations, or substance-emitting stationary activities from which an accidental release of anhydrous ammonia may occur; which belong to the same industrial group; which are located on one…...

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EPA’s Risk Management Program Safer Communities – Power Loss

Whether caused by a natural hazard or some other event, power loss at hazardous chemical facilities can lead to a variety of negative impacts. Pumps and compressors may stop running, stirrers may quit mixing, lights may go out, and instruments and controls may malfunction. These equipment outages can lead to tank overflows, runaway chemical reactions,…...

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EPA’s Risk Management Program Safer Communities – Hazard Evaluation Amplifications

A hazard evaluation is defined as the identification of individual hazards of a system, determination of the mechanisms by which they could give rise to undesired events, and evaluation of the consequences of these events on health (including public health), environment, and property. These evaluations often use qualitative techniques to pinpoint weaknesses in the design…...

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