Bryan Haywood

Owner / operator compliance audit timeline

Must an owner or operator conduct and document a compliance audit at the time of an update required under §68.190 if the update is made within three years of the original RMP submission?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Process Safety Information… sweating the small stuff (Flange Bolts/Rods)

In the world of process safety, every little detail adds up; so as one of my favorite bosses always said… “sweat the small stuff”!  This became crystal clear during an incident investigation where a flanged connection was the point of release.  Most people look at a flanged connection as a simple means to connect to…...

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Designed with maintenance in mind, NOT! (Ammonia Refrigeration header detection)

Several years ago, we discussed this picture in terms of a Relief Design Basis, the NH3 vent header sensor placement in terms of NFPA 70 HAZLOC, and the risk of doing maintenance/calibration on the sensor when the process is live.  As usual, I got some nice feedback, and the usual haters chimed in that I…...

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Pressure Testing GONE BAD (Fire Protection System)

On March 6, 2018, a pipefitter (49) was hit in the chest by a pressurized 12-inch diameter polyvinyl chloride (PVC) pipe during a hydrostatic pressure test of a fire suppression system. The sudden pipe movement was attributed to a pipe joint connection failure in a buried section of the pipeline. The failure was due to…...

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PRCS fatality in Flour Tanker Truck (Nitrogen – O2 Deficiency)

On November 19, 2019, an employee was unloading his semi-truck tanker of flour and hooked up a blower hose that is powered from the truck’s transmission. The employee climbed to the top of the tanker while trying to get a better seal and opened the hatch before entering. Emergency Services was contacted and removed the…...

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PRCS fatality in Mine Water Treatment valve pit (5% O2 Deficiency w/ Methane @ 15%)

At 2:00 p.m. on November 28, 2017, Employee #1 and a coworker were looking for drainage valves at a mine water treatment pond facility. Employee #1 went down a ladder into a manhole next to one of the ponds to look for the valve. Employee#1 fell off of the ladder as soon as his head…...

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2019 OSHA Respiratory Protection (1910.134) activity by Industry Sectors

Here is a look at OSHA’s Respiratory Protection compliance activity in 2019 (October 2018 – September 2019). As you can see, OSHA did 1,298 inspections and issued 2,931 citations for a total of $3,808,871 in fines. Here is a quick breakdown of activity: NAICS Code: 33 / Manufacturing was #1 in # of citations with…...

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A chicken processor loses its appeal regarding MI procedures (j)(2) and inspections (j)(4)

A chicken processor petitioned for review of a determination by the Occupational Safety and Health Review Commission (the “Commission”) that it violated various regulations of the Department of Labor’s Occupational Safety and Health Administration (“OSHA”). We find no error, so we deny the business’s petition.  The Secretary of Labor (“Secretary”) is charged by statute “with…...

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Process safety failures led to the fatal Styrene release in India last month

Today, the Indian government released its investigation findings regarding the fatal Styrene release on May 7, 2020, which killed 12 citizens and hospitalized 585 others.  This incident, like the many before it, came about by a number of failures the facility/company made in the management of their Styrene inventory.  In the light of the root…...

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EPA RMP citations @ polymer manufacturing plant (Flammables & $48K)

PLEASE NOTE this entire inspection citation is based on the facility not having their piping labeled per ASME A13.1 – A13.1-2015, Scheme for the Identification of Piping Systems Respondent is the owner of a polymer manufacturing plant and based on the observations of EPA inspectors during the Inspection, EPA has determined that Respondent has handled…...

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Canada is proposing some interesting revisions to their Confined Space standard

In 2014, Part XI – Confined Spaces was identified as a priority for review by the Labour Program’s Occupational Health and Safety Advisory Committee (OHSAC). The OHSAC made up of representatives from the Labour Program and employee and employer groups, conducted an in-depth review of Part XI between 2014 and 2017. The proposed changes are…...

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The sad state of Hazard Communications in safety

It’s been 8 years since we have been using the Globally Harmonized System for our Hazardous Communications.  This much-needed update to OSHA’s HAZCOM standard was intended to correct many bad practices and to “harmonize” the USA with the rest of the world.  One of the big drivers for this change was the need to formalize…...

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