Bryan Haywood

EPA issues RMP citations @ fruit and vegetable processing facility (NH3 & $203K)

Respondent owns and operates a facility that processes and packages fruit and vegetable products. Between June 5 and June 7, 2018, EPA performed an inspection of the Facility pursuant to Section 112(r) of the CAA, Sections 304–12 of the Emergency Planning and Community Right-to-Know Act, and Section 103 of the Comprehensive Environmental Response, Compensation, and […]

EPA issues RMP citations @ cold storage (NH3 & $115K)

Respondent owns and/or operates a refrigeration-based cold storage facility which is located within a populated residential, commercial, and industrial area and is adjacent to a significant roadway. At the Facility, Respondent handles, stores, and uses, and has handled, stored, and used anhydrous ammonia.  On April 24, 2018, EPA performed an inspection of the Facility pursuant

EPA issues RMP citations @ CO2 liquification plant (NH3 & $127K)

Respondent owns and operates a carbon dioxide liquification plant, which uses anhydrous ammonia to produce and refrigerate liquid carbon dioxide. On September 19, 2017, EPA performed an inspection of the Facility pursuant to Section 112(r) of the CAA, Section 103 of CERCLA, and Sections 302-312 of EPCRA. Based upon the information gathered during this inspection

EPA issues RMP GDC citations @ chemical wholesale distributor (Flammable Liquids & $0)

Respondent is the owner and operator of a chemical wholesale distributor that repackages and custom-blends chemicals. Respondent formulates two mixes, paper adhesives and lacquer thinners, for sale. Respondent currently operates lacquer thinner mixing and flammable liquid storage systems at the Facility. With regard to the lacquer thinner mixing and flammable liquid storage systems, Respondent produces,

Another example of something CRITICAL but not required by OSHA/RAGAGEPs (Electrical Classifications)

A few years ago I wrote a piece about identifying ALL equipment, especially valves, with a unique identifier.  The purpose of that posting was brought about by a lot of facilities challenging our PHA, II, Audit findings/recommendations that all equipment be identified with a unique identifier in the field, on P&ID’s, in SOPs, LOTO procedures,

Anhydrous Ammonia and CFATS (2021)

To reduce the risk of more than 300 chemicals of interest (COI) being weaponized, the Cybersecurity and Infrastructure Security Agency’s (CISA) Chemical Facility Anti-Terrorism Standards (CFATS) program identifies and regulates high-risk chemical facilities to ensure appropriate security measures are in place. Under CFATS, a chemical facility is “any establishment that possesses or plans to possess

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