Bryan Haywood

OSHA issues PSM citations @ chemical company (Fluorocarbons & $232K)

Exposure to dangerous toxins at an Alabama chemical manufacturing plant lead to the deaths of two (2) workers and sickened another worker after the employer failed to provide appropriate protective equipment and implement safe work practices during maintenance activities on chemical processing equipment.  An OSHA investigation found the exposure occurred while the workers were conducting […]

EPA issues RMP citations @ manufacturing facility (LPG and Isobutane & $144K)

On September 15, 2021, Respondent acquired ownership and commenced operation of the manufacturing facility. Isobutane is a “regulated substance” pursuant to 40 C.F.R. § 68.3. The threshold quantity for Isobutane, as listed in 40 C.F.R. § 68.130, is 10,000 pounds. Propane is a “regulated substance” pursuant to 40 C.F.R. § 68.3. The threshold quantity for

Rotary Valve/Airlock and Lock-Out/Tag-Out Hazards (OSHA SHIB 2021)

Rotary valves/airlocks (rotary valves) are devices with close-fitting, revolving blades/vanes installed inside industrial equipment to control the flow of materials through a process (see Figure 1).  Rotary valves are used in many industries and functions. A common example (Figure 2) is an airlock used in a pneumatic conveying system to dispense material while maintaining system

Mitgating Risks, Decision Making, and TDODAR

We cannot eliminate risk. It’s a consequence of the uncertainty in our situations and the world around us. It’s essential to think about how we can mitigate risks in the workplace. Also, consider the tools we can provide to make our colleagues more aware of risk in themselves and others.  Risk assessments are a useful

The SHELL Model

The SHELL Model is a conceptual tool used to analyze the interaction of multiple system components.  The SHELL Model contains the following four (4) components: SOFTWARE (S): procedures, training, support, etc. HARDWARE (H): machines and equipment ENVIRONMENT (E): the working environment in which the rest of the L-H-S system must function and LIVEWARE (L): humans

The circle of safe(ty)

One of my favorite movies is “Meet the Parents” and in this movie, the bride’s to-be dad, Jack, had his “circle of trust”.   Well not to poke fun at the concept, we also have the “circle of safety”.  It is core in each and every one of us.  When we feel like we can trust

Respiratory protection against COVID-19 for employees with religiously mandated facial hair (OSHA LOI)

Generally, you asked OSHA to clarify whether loose-fitting powered air-purifying respirators (PAPRs) are a permissible alternative to N95 respirators where respiratory protection is required to protect workers from exposure to SARS-CoV-2, the virus that causes COVID-19. Additionally, you asked OSHA to clarify the interplay between the Respiratory Protection Standard and other laws that may require

The COVID ETS is not like 1910.1030!

It seems there is a faction of safety professionals who want to claim that if OSHA’s blood-borne pathogens standard is “legal”, then so would the COVID ETS.  But these two standards are nothing alike.  For example, OSHA defined “occupational exposure” in 1910.1030 as: Occupational Exposure means reasonably anticipated skin, eye, mucous membrane, or parenteral contact

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