Bryan Haywood

Hexane explosion in an oil extraction plant (Double Fatality – PRCS)

The accident occurred in the hexane-based rapeseed oil extraction process. After grinding the seed and obtaining meal that is then steam-cooked (100°C), pressing in a continuous screw press is used to obtain 2/3 crude oil and flakes containing 1/3 oil. This oil is extracted from the flakes in the extraction process: the flakes are transported…...

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EPA issues RMP citations @ water treatment facility (WRONG CHEMICAL – WRONG TANK incident, 2,000 lb Cl2 release & $66K)

Chlorine, CAS No. 7782-50-5, is an extremely hazardous substance regulated and listed in 40 C.F.R. § 68.130. As the owner and operator of a stationary source, with respect to the use and storage of ferric chloride and sodium hypochlorite, Respondent has a duty under the General Duty Clause, Section 112(r)(1) of the CAA, to design…...

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EPA issues RMP citations @ poultry processing facility (NH3 & $124K)

The Respondent processes and freezes poultry products for distribution. The Respondent has two systems which include Anhydrous Ammonia at the Facility. The Respondent had one RMP program level 3 covered process (anhydrous ammonia refrigeration systems) which store or otherwise use a regulated substance in an amount exceeding the applicable threshold. The Respondent’s poultry freezing processes…...

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Cal/OSHA Cites Four Employers $1.75 Million for Safety Violations in Death of Worker at a refinery

The Cal/OSHA Process Safety Management Unit has cited a refinery and three contractors a combined $1,753,375 for serious safety violations following a confined space death of a 35-year-old worker who suffocated in a regenerator overflow well. Cal/OSHA inspectors cited three of the four employers with willful and serious violations after determining that they failed to…...

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The Safety Process through the eyes of a Quality Assurance Process

As many of you know I have taken on a new client (full time) in 2022 and my role in this organization is to build a safety management system (SMS).  And let me tell you what, if you thought explaining a RAGAGEP to management was difficult – try explaining that safety is a “process” and…...

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EPA issues RMP citations @ chemical manufacturing facility (Cl2, CHCl3, CH3Cl, C2H3Cl & $500K)

The respondent is the owner and operator of a chemical manufacturing facility. EPA conducted an inspection of the Facility on May 1-4, 2018, to determine the Respondent’s compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68. The following chemicals are “regulated substances” pursuant to 40 C.F.R. § 68.3. The threshold quantity for…...

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EPA issues RMP citations @ ice-making plant (NH3 & $170K)

Respondent owns and operates an ice-making plant that uses anhydrous ammonia in a refrigeration “process”. In 2016, Respondent filed a Program 3 RMP for the Process and reported that it used 22,000 pounds of anhydrous ammonia. In accordance with 40 C.F.R. § 68.10(a) and (f)-(h), the Respondent’s use, storage, and handling of anhydrous ammonia in…...

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EPA issues RMP citations @ warehouse (Flammables & $109K)

Respondent is a limited liability company that operates as a public warehousing facility.  The term “have a general duty in the same manner and to the same extent as section 654 of title 29 [of the U. S. Code]” means owners and operators must comply with the General Duty Clause in the same manner and…...

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Understanding your Pressure Vessel(s) “Birth Certificates”

I like to explain the documentation for our pressure vessels much in the same context as our birth certificates.  For every pressure vessel in service today, we must have that vessel’s U-1 Form.  And please don’t tell me about the OSHRC decision stating otherwise.  I really don’t care what a group of lawyers think about…...

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Human Factors 101… causal analysis

We are working to implement a formal root cause and corrective action process for a client. The industry has a very different view and approach to what I have come to know over the last 30 years as Human Factors. I think my friends “down under” are reading my mind or my articles at SAFTENG…...

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Heiarchy of Controls and the “Elimination and Falls”

As we approach The National Safety Stand-Down To Prevent Falls in Construction (May 2-6, 2022) I am reminded of how some view “Elimination” within the Hierarchy of Controls.  The number of postings on social media calling for the “Elimination of falls” in the construction industry has me asking… can this actually be done?  One such…...

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