Bryan Haywood

Incorporated by Reference (IBR) database

Incorporated by Reference (IBR) is the act of including a second document within another document by only mentioning the second document.  This act, if properly done, makes the entire second document a part of the main document. Incorporation by reference is found over 1,445 times in OSHA standards, with 949 being related to the General

Kansas Department of Agriculture updates its Anhydrous Ammonia Storage Tank policies (2/13/2021)

The following policy updates apply to anhydrous ammonia storage tanks (tanks) in the state of Kansas as of 2/13/2021.  The state has issued new retirement dates for the “railcars” that have been modified and used as fixed storage tanks for decades. This policy is intended to apply to the Fertilizer Industry within the state.  It

Actions Needed to Improve Reporting of Summary Injury and Illness Data (2021)

GAO’s analysis of Occupational Safety and Health Administration (OSHA) data showed that the number of recordkeeping violations OSHA cited fluctuated over 15 years. An April 2012 federal court decision (that effectively limited the time period for citing these violations) and a January 2015 expansion of OSHA’s rule for reporting severe injuries and illnesses coincided with

FAILURES of true “facility siting” – our “zoning” process is broken and dangerous!

Having spent my entire safety career in chemicals, I have always been amazed when communities rezone and permit housing developments such as apartments/condos with high density populations within spitting distance of chemical/processing facilities and then the city officials are furious when there is an event that causes disruption in these housing developments.  This story is

EPA RMP citations @ speciality chemical plant (C3H6O, NH3, C6H13N & $27K)

Respondent is the owner and/or operator of the Facility and has developed an RMProgram accidental release prevention program for the Facility. On July 23, 2019 – July 25, 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

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