Bryan Haywood

Massachusetts Office of Technical Assistance Advisory Preventive Hazard Evaluation for Process Safety

Massachusetts Fire Code hazardous material processing regulation (527 CMR 33)  requires a hazard evaluation or limited process safety program for many companies that have never faced this requirement before, (though many companies have been essentially performing these tasks as good practice).  Many companies covered by this regulation must now document that a hazard evaluation has

EPA issues RMP citations @ bakery (NH3 & $80K)

The Respondent manufactures bread and bakery products. The Respondent’s bakery processes meet the definition of”process” and “covered process “, as defined by 40 C.F.R. § 68.3. The Respondent had one RMP program level 3 covered process (anhydrous ammonia refrigeration system) which stores or otherwise uses a regulated substance in an amount exceeding the applicable threshold.

Is Auto-Refrigeration an “inherent safeguard” for liquidfied pressurized gases Worst-Case Release scenario

As we saw in Jordan last week, gases stored as liquids can “auto-refrigerate” in large-scale accelerated releases.  In the aftermath pictures, we can see a clear frost line along the bottom of the ISO container, which is evidence of a refrigerated liquid level within the container. (See pic and explanation below)

US Appeals Court defines “Emergency Response”

Full Disclosure:  This is a horrible decision, based on legal matters and not on safety and health.  So use it wisely! In this case, we must decide whether the Power Generation Plant violated OSHA’s Hazardous Waste Operations and Emergency Response standard when employees at one of its power plants responded to an ammonia release without

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