Bryan Haywood

EPA RMP Citations @ chemical manufacturer (Isobutane & $4K)

/ Chemical Process Safety (PSM/RMP) /

I normally do not share cases that are handled as Expedited Settlement Agreements (ESA) but this one incldued three (3) very common findings during our PSM/RMP audit, so I am sharing this case: Source: https://yosemite.epa.gov/OA/RHC/EPAAdmin.nsf/Filings/55591B2C4849A1E585258CBB006EE6A9/$File/CAA-01-2025-0037%20Bic%20Consumer%20Products%20Final%20Order.pdf… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Bypassed Safety Device Deficiencies (BSEE)

/ Chemical Process Safety (PSM/RMP), Hazardous Materials, OSHA Compliance, Safety Management System /

A team of auditors identified a potential risk associated with bypassed safety devices and inconsistent interpretation of regulations after multiple incidents of noncompliance were issued, associated with the operator’s failure to comply with 30 CFR 250.869 and 30 CFR 250.870 in 2025. The BSEE Performance-Based Risk Inspection (PBRI) covered five assets (all production platforms) in…...

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Fatigue Cracking of ¾-Inch Pipe Nipple Results in Gas Release (BSEE)

/ Chemical Process Safety (PSM/RMP), Hazardous Materials /

The Bureau of Safety and Environmental Enforcement (BSEE) has investigated a recent offshore gas release incident resulting from the failure of a ¾-inch pipe nipple connected to a compressor suction scrubber (Figure 1). The failure led to an immediateplatform shut-in and a full muster of personnel onboard. The released gas posed a significant safety risk,…...

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NSC’s FREE Maturity Assessment and Action Plan

/ Safety Management System /

The NSC Safety and Health Maturity Assessment is a free tool that helps organizations identify where they are on their safety journey and offers next steps to improve safety. Please take 15 minutes to complete the assessment, then share your feedback via a short survey. CLICK HERE… Membership Required You must be a member to...

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Benzene Railcar on fire in derailment (a lot to look at)

/ Emergency Response, Hazardous Materials /

When you see it… Flammable liquid railcar, in fact, it’s a carcinogenic flammable liquid, a Benzene railcar on fire. I know it’s hot as heck in MS this time of year, but dang: Just a lot of opportunities! The better option: Set up an unmanned(!!!) monitor nozzle, lay a couple hundred, if not 1,000s, of…...

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Consider Human Error and Domino Effects (EPSC Learning Sheet July 2025)

/ Chemical Process Safety (PSM/RMP), Flammable Liquids, Hazardous Materials, Human Factors Engineering /

At an Ethylene unit in the Czech Republic (2015), when swapping over cooling water supply lines during a flowmeter calibration, the operator made a simple mistake. While intending to open valve #3 on the spare supply line, he closed the identical valve #2 instead, shutting off all cooling water to the Light Ends columns. A…...

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How can I tell if a facility is doing their SCBA inspections “by the book” each month?

/ Emergency Response, OSHA Compliance, Respiratory Protection /

A trick question I learned long ago, when it was used on me, is one I use today when auditing a facility that has SCBAs for “Emergency Use Only” (e.g., an ERT). As we are walking to the ERT cage/trucks, I casually ask if the facility fills its bottles/cylinders or if they have a breathing…...

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IDLH Value Profile: Hydrogen Bromide CAS® No. 10035-10-6

/ OSHA Compliance /

This technical report presents the scientific basis, toxicologic data, and risk assessment meth­odology used to derive a health-based immediately dangerous to life or health (IDLH) value for hydrogen bromide (CAS No. 10035-10-6). The IDLH values are based on the scientific rationale and logic outlined in Current Intelligence Bulletin (CIB) 66: Derivation of Immediately Dangerous to…...

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OSHA renews NEP to address amputations in manufacturing

/ OSHA Compliance /

OSHA has renewed its National Emphasis Program on Amputations in Manufacturing Industries, focused on preventing amputations in manufacturing workplaces. Under the renewed program, which aims to identify and mitigate hazards that could lead to amputations and other injuries in the manufacturing sector, OSHA will conduct inspections of manufacturing facilities to ensure compliance with safety practices…...

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Is anyone surprised? Who thinks this is a “driver error”?

/ Human Factors Engineering, OSHA Compliance /

This footage would be great to use in a management setting to discuss failures in our safety process. My plant managers (all four of them) would immediately make the snarky comment about not having a “bullseye” painted on the bucket. It was simply a matter of time!!! I/m betting this “practice” was “routine” (Reason’s HF…...

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