Bryan Haywood

Anhydrous Ammonia, nitrification inhibitor, and EPCRA Sections 311 and 312 reporting

Back in December 2017, I wrote an article explaining how this new nitrification inhibitor in the ammonia fertilizer industry would impact the facility’s PSM/RMP programs.  I received a lot of questions and nasty grams from that article, but one thing I forgot to mention is how this new “blending” operation changes the retail locations EPCRA […]

Updated PSM/RMP Audit Checklist with EPA Emergency Response updates

For SAFTENG clients and members, I have updated my PSM/RMP audit checklist (the old OSHA PQV checklist) with EPA’s most recent amendment regarding the Emergency Response requirements for Responding and Non-Responding facilities.  Keep in mind that these new requirements are “officially” ONLY required when the facility is an RMP facility; if the process(s) is ONLY

OSHRC vacates fatal PRCS citations involving gasoline tank cleaning (OSHRC said it was “construction work”)

The company is a fuel filtration and tank cleaning company. In December 2014, an employee was found unresponsive and later died from gasoline inhalation while cleaning tanks at a construction site in Daytona Beach, Florida. Following the incident, OSHA conducted an inspection and issued an 11- item serious citation for violations of 29 C.F.R. §

Are you worried about a hydrostatic relief system discharging an HHC/EHS into an occupied space?

For nearly 25 years I have seen CLOSED relief systems used successfully on a multitude of processes involving Extremely Hazardous Substances (EHS) and for many years I have been proposing they be used in the Ammonia Refrigeration industry.  The leading trade group for ammonia refrigeration has had a long-standing position against the need for hydrostatic

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