Bryan Haywood

99% Polyester and 1% Carbon Fiber in HAZLOCs

Call me crazy, but this just blew me away.  And once again we find ourselves faced with an “industry practice” vs. “RAGAGEP”.  We were at a facility several years ago where pieces of equipment are painted and this painting is a huge pride of the manufacturing sector and hence they have some very tight QA…...

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When is a “gas detection” or “oxygen depletion alarm” system required?

We often get asked: Do I need to install a gas detector in the room? Well, it’s pretty easy in my state, as in most cases we have dealt with, the state fire/HAZMAT code required it.  The code includes basic requirements for ALL gas detection systems and covers: For example, meat production facilities use Nitrogen…...

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Canada is amending it’s Federal PRCS standard

Just an FYI for those of you outside of Canada… there are fourteen (14) jurisdictions in Canada – one (1) federal, ten (10) provincial, and three (3) territorial each having its own occupational health and safety legislation. Federal legislation covers employees of the federal government including Crown agencies and corporations across Canada.  The federal health…...

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EPA issues RMP citations @ cold storage (NH3 & $31K)

Respondent operates an ammonia refrigeration plant with 50,629 pounds of anhydrous ammonia which is an RMProgram level 3 covered process. On March 27, 2019, the EPA conducted an on-site inspection of the RMProgram related records and equipment for the purpose of assessing the Respondent’s compliance with the RMProgram requirements and the implemented recognized and generally…...

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Atmospheric storage tank collapses from rapid cooling after a steam cleaning

After cleaning with steam a tank was quenched with cold water to shorten the cooling time (not normal practice). The tank vent was not calculated for the vacuum resulting from this rapid quenching operation, resulting in a collapsed tank (without liquid release).  SOURCE: EPSC Learning Sheet… Membership Required You must be a member to access...

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Liquid Nitrogen and the State Fire/HAZMAT Codes (Part III – Use and Handling)

Back in May 2020 and January 2021, I posted the first two parts of this three-part series on the hazards of Liquid Nitrogen.  These articles were prompted by the OSHA and State Fire Marshal cases involving fatalities at cattle and human sperm bank businesses.  Then, in January of this year, we had the GA Food…...

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Operating procedures and Operational Discipline

How often do the operators within your PSM/RMP covered process(s) actually use their operating procedures?  Hourly, Daily, Weekly, Monthly, every three years during refresher training? How often do we think they should be using their operating procedures?  How many times have you pulled the SOP binder off the shelf to find it covered in dust…...

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PAPR’s, APF’s and big assumptions = bad decisions!

What is the Assigned Protection Factor (APF) for a Powered Air-Purifying Respirator (PAPR)?  Most people will claim 1,000 and with that, we are already off the rails!!!  SAFTENG members can refer back to my 2015 article (What is the ACTUAL assigned protection factor for Powered Air Purifying Respirators (PAPR) WITHOUT a tight-fitting facepiece?) where I…...

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The Wizard of Oz of safety (Part 2)

Have you ever seen the Wizard of Oz?  It is a classic and I highly recommend it, even as an adult first-time viewer.  But the theme of the movie can relate to the safety profession.  During my internship in the summer of 1992, I worked with a great safety professional, Garth Newman.  Garth was preparing…...

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Could 1910.504 become the standard for “Voluntary Use” of respirators?

OSHA titled the standard, “Mini Respiratory Protection Program“, but when we read it we see that it could very easily be applied to “voluntary use” NOT associated with COVID 19. So I ask, could this “emergency standard” become permanent and have 1910.134(c)(2) refer to this “standard”? OSHA has made it VERY clear that at this…...

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NIOSH issues standard(s) for “New Performance Masks for Workplaces”

NIOSH is recommending a new standard in face masks for workplaces, called Workplace Performance and Workplace Performance Plus masks Manufacturing masks that comply with the new NIOSH criteria can help protect people in the workplace from SARS-CoV-2, the virus that causes COVID-19. These masks CANNOT be used as a replacement for respiratory protection when it…...

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