Bryan Haywood

EPA and OSHA are getting serious in their RMP enforcement efforts, especially with NH3 refrigeration and refinery piping inspections!

Those that follow my PSM & RMP Citations / Analysis postings most likely have noticed a significant change in the level and depth that EPA and OSHA are conducting their RMP and PSM inspections.  They have cited many more RAGAGEP issues and now dig deep into PHA’s and SOP’s than they ever had before.  This […]

EPA RMP citations @ refinery (Flammables & $344K)

Respondent is the owner and/or operator of a Refinery that uses, handles, and/or stores more than a threshold quantity of Flammable Mixture and Hydrogen fluoride/Hydrofluoric acid, which are regulated substances, as specified at 40 C.F.R. ยงยง 68.115 and 68.130. From August 15 to August 18, 2016, authorized representatives of the EPA conducted an inspection of

Contractor’s lack of a PPE HAZ Assessment, saved by the host facility’s Safe Work Permit (OSHRC)

A contractor was performing rust corrosion removal and prevention services on pressurized piping at a chemical plant in Freeport, Texas. In October 2016, two contractor employees were seriously injured when a pipe ruptured, releasing trichlorosilane. Following an inspection, OSHA issued the contractor a two-item serious citation. The first item, grouped for penalty purposes, alleges violations

OSHA HAZWOPER Inspection Activity (10/2019 thru 9/2020)

This is OSHA’s HAZWOPER (1910.120) Inspection Activity for their 2020 Fiscal year (October 2019 through September 2020).  I have broken down the data by # of Citations, # of Inspections, Penalty $’s, and NAICS Industry Classification.  As you can see, OSHA issued 38 citations from 19 inspections for a total of $130,373 in fines.  Here

OSHA Respirator Inspection Activity (10/2019 thru 9/2020)

This is OSHA’s Respiratory Protection (1910.134) Inspection Activity for their 2020 Fiscal year (October 2019 through September 2020).  I have broken down the data by # of Citations, # of Inspections, Penalty $’s, and NAICS Industry Classification.  As you can see, OSHA issued 2,408 citations from 1,018 inspections for a total of $4,267,147 in fines. 

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