Bryan Haywood

Interesting OSHA guidance on “change-out schedules” for respirator cartridges

In 2019, OSHA published a respiratory protection guide for Roofing Contractors, but since I do not work in the construction field I did not pay much attention to it.  But today I found some never published guidance from OSHA regarding how an employer can establish a “change-out schedule”.  I may have missed this in all…...

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Lessons to be learned… Respiratory Protection Program is more than OSHA’s Free PowerPoint

I really don’t understand the mindset of these companies… they have a horrible accident, and rather than recognize something failed and needs to be fixed, they hire lawyers to fight all the OSHA citations rather than competent/qualified safety professionals to fix it all.  These citations were like “taking candy from a baby” because the company…...

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OSHA Grain Bin citations after engulfment fatality ($69K)

OSHA cited a grain, lumber, and supply company for grain-handling safety violations after corn engulfed an employee clearing clumps in a grain storage bin. First responders were able to rescue the worker. The company faces $69,010 in penalties. OSHA cited the company for two willful and four serious violations for exposing employees to engulfment hazards…...

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EPA RMP citations @ chemical manufacturing and distribution facility (Anhydrous and Aqua Ammonia & $79K)

Respondent owns and operates the chemical manufacturing and distribution facility. Anhydrous ammonia is a “regulated substance” pursuant to 40 C.F.R. § 68.3 with a threshold quantity, as listed in 40 C.F.R. § 68.130, of 10,000 pounds. Ammonia in the concentration of greater than 20% is a “regulated substance” pursuant to 40 C.F.R. § 68.3 with…...

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PRDs and their inspection and overhaul frequencies (API 576)

A baseline of every 5 years is recommended; however, there are some critical exceptions that would require more frequent inspections. And if the process is CLEAN (e.g., Non-Fouling), we could go 10 years WHEN the manufacturer permits. Here is a breakdown of these frequencies, using API 576 and NB Part 4…. Membership Required You must...

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Why can’t we use the PRESSURE CHANGE TEST in ASME Section V for leak testing B31.3 piping?

ASME B31.3 does not permit the use of an “ASME Section V Pressure Change Test” as a substitute for the mandatory leak testing requirements (hydrostatic, pneumatic, or initial service leak test) defined in Chapter VI of the B31.3 Code. Why It Cannot Be Used as a Substitute:… Membership Required You must be a member to...

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Where does it require I have an Oxygen Monitor when I use liquid Nitrogen?

OSHA may use its General Duty Clause (GDC) to require employers to install oxygen monitors in areas where inert cryogenics are stored or used.  But I like to use codes/standards (e.g., RAGAGEPs) to guide my safety engineering for these hazardous processes, even though PSM/RMP does not cover them.  To do this, I turn to the…...

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Two Kansas Companies Fined $1 Million Each In Atchison Chlorine Gas Case

Sorry, I have not seen any actual citations or details of how this incident occurred, but I will update if I get anything. A chemical supplier and an Ingredients’ facility have been fined $1 million each for violating the federal Clean Air Act when a cloud of toxic chlorine gas was released over Atchison, Kan.,…...

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EPA RMP citations @ Refinery (Flammables & $?????)

I am not sure how much of the $4 million was for RMP, as there were other issues in this Consent Decree and I have only pulled out the RMP issues. On or about September 4, 2017, heater tube 23 ruptured in the CRU2/HTU2 charge heater process due to creep, a molecular failure mechanism that…...

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VA-OSHA Hazard Alert regarding hand sanitizer with 80% Alcohol

Last week, VA-OSHA posted this Hazard Alert regarding hand sanitizers with 80% alcohol.  Now I am not aware of any studies that differentiate the hazards of 80% versions from 70% and 65%% versions or of any incidents where static ignited the sanitizer when the user touched a grounded surface.  But we do know that Alcohols…...

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OSHA PSM citations @ chemical plant (Butadiene & $514K)

OSHA has cited a texas chemical company for exposing employees to workplace safety and health hazards after a fire and explosion at the plant in November 2019. The company faces $514,692 in fines. OSHA opened an investigation after vapor formed at the base of a butadiene finishing tower ignited and caused several explosions and fires…....

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Determining frequency of emergency coordination activities (changes to response capabilities)

Today, the EPA’s RMP Info Center published the following guidance on the REVISED emergency coordination activities in the RMP Rule.  The Risk Management Program regulations require owners and operators of stationary sources to coordinate their response needs ANNUALLY, or more frequently if necessary, with local emergency planning and response organizations (40 CFR §68.93(a)). Are stationary…...

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