Bryan Haywood

OSHA’s proposed Fire Brigade/ER standard – Part I

Have you seen OSHA’s proposed ER standard?  It will replace 1910.156 and encompass all aspects of emergency response, such as firefighting, fire rescue, emergency medical service, technical rescue (rope/high angle, cave, etc.), vehicle/machinery rescue, water rescue/recovery (land/shore-based, Swiftwater, underwater), search and rescue (urban, mountain, wilderness).  I have gone through the proposed standard and structured it

EPA issues RMP citations @ petrochemical facility (SO2, HCL, VC, C3H6 & $447K)

Respondent operates a petrochemical manufacturing process at the Facility, utilizing regulated substances to produce vinyl chloride monomer, meeting the definition of ” process”, as defined by 40 C.F.R. § 68.3. Sulfur dioxide, hydrogen chloride, vinyl chloride and propylene (collectively, “regulated substances”) are each a “regulated substance” pursuant to 40 C.F.R. § 68.3. EPA conducted an

EPA issues RMP citations @ Brewery (NH3 & $37K)

Respondent is the owner and/or operator of a Brewery and has registered an RMPlan with the EPA for its Facility and has developed an RMProgram accidental release prevention program for the Facility. At its Facility: Respondent operates an ammonia refrigeration plant. Respondent has on-site for use, 160,300 pounds of anhydrous ammonia. Respondent has one RMProgram

Safety should not be #1

WTH?  Did Haywood just say that?  Yep – I am afraid I did and I mean it.  Now my personal actions do not reflect that belief, as I am a safety professional and I want every decision you make to be one based on YOUR SAFETY.  But as a business, safety can never be #1! 

How do we make “safety a value”?

Buzz words… oh how I have come to hate them.  In my earlier days in this profession, it was called “flavor of the month safety” as we had some catchphrase or “program” we’d implement to try and break through the “mental fog” that caused workers to work unsafely.  Then came along the “silver bullet of

Ventilation System Design basis?

We do a lot of work in flammable atmospheres so yes we have rather high standards for what “minimal compliance” looks like.  We recently came across this situation while performing an assessment for a facility that has suffered from a flash fire months earlier.  During our walk-thru of the area (they knew we were coming)

1910.178 3-year evaluations and 1910.147 periodic inspections

Both 1910.178 and 1910.147 have requirements that we periodically evaluate employees’ performance in their ability to perform LOTO and drive PITs in the manner in which they were trained.  As I have discussed many times, just doing annual LOTO training without some type of “field verification” that the authorized employees are functioning within the program’s

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