Bryan Haywood

Inherently Safer Technology Reviews (NJ TCPA)

On March 25, 2008, the State of New Jersey adopted rules requiring facilities regulated under the Toxic Catastrophe Prevention Act (TCPA) Program, which is PSM/RMP to those of us outside of the state of New Jersey, to perform Inherently Safer Technology (IST) reviews. Both OSHA and Federal EPA have tried to incorporate the IST model…...

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OSHA issues Regional Memo on Enforcement Guidance for Use of Respiratory Protection Equipment Certified under Standards of Other Countries or Jurisdictions During the Coronavirus Disease 2019 (COVID-19) Pandemic

MEMORANDUM FOR: REGIONAL ADMINISTRATORS, STATE PLAN DESIGNEES THROUGH: AMANDA EDENS, Deputy Assistant Secretary FROM: PATRICK J. KAPUST, Acting Director Directorate of Enforcement Programs SUBJECT: Enforcement Guidance for Use of Respiratory Protection Equipment Certified under Standards of Other Countries or Jurisdictions During the Coronavirus Disease 2019 (COVID-19) Pandemic   This memorandum provides interim guidance to Compliance…...

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OSHA PRCS citations @ University (Steam Vault & $235K)

OSHA cited three employers – a University, a Mechanical contractor and an HVAC contractor – for exposing workers to permit-required confined space hazards associated with underground steam vaults. Proposed penalties for the three companies total $235,962.  OSHA received an employer-reported referral from the mechanical contractor after an employee suffered burns from a release of steam…...

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And you wonder why OSHA writes these standards (Exit height and Working Order)

In this one, we get a 2-for-1 special!!!! First, the egress path height… 1910.36(g)(1) The ceiling of an exit route must be at least seven feet six inches (2.3 m) high. Any projection from the ceiling must not reach a point less than six feet eight inches (2.0 m) from the floor. and then the…...

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Free EHS Web Training (Listing of Resources)

From my friend Bill Geddings… In an effort to help EHS professionals who are missing conferences, local professional development meetings and other training opportunities that will allow us all to maintain certifications and our competencies please share known online learning opportunities.  These can be environmental, occupational health, safety, leadership, emergency response, etc. I will share…...

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When a business converts to handling flammable liquids for the pandemic response (Part 2 – Indoor Storage)

Earlier this week I explained the OSHA requirements for storing Flammable Liquids “outside”, using Ethanol as my example since so many businesses have been converted over to making hand sanitizers, many of which have never managed such a large inventory of flammable liquids.  Part 2 is to cover those businesses who wish to store their…...

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Outdoor Storage of Flammable Liquids in containers and portable tanks

The humanity and compassion that many ordinary businesses are showing during this pandemic are heartwarming and patriotic.  But it is also very concerning and quite frankly dangerous to see some of the images from their public announcements of their efforts.  As a profession, we need to step up and help these businesses manage their hazardous…...

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Don’t forget “building construction” in your PSSR

Although the idea of this article originated from a PSSR debacle on a new process construction project, the information will apply to ALL building construction and so I have put this in the OSHA Compliance Category rather than the Chemical Process Safety category.  Late last year we were finishing up a longterm project with a…...

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Compliance in a time of COVID-19 Pandemic

Brian Chapin, Compliance Services Manager NOTE: This article is by my good friend and colleague Brian Chapin @ RC&E in Forth Worth, TX.  In full disclosure, RC&E has been a corporate member for several years.  Brian was gracious in allowing me to post his work directly at SAFTENG as some of you were having issues…...

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NEVER use the HHC/EHS as your pressure/leak testing media

On June 29, 2005, an operator was involved in the following maintenance activities in the Chloropyridines Complex at the employer’s chemical manufacturing facility. He was returning a reactor vessel to service and WAS ATTEMPTING TO DO A PRESSURE AND LEAK TEST USING CHLORINE GAS. The pipeline was supposed to be pressure tested with nitrogen gas…...

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This is why ASME B31 series requires us to have written procedures for pressure and leak testing the piping

On March 13, 2007, Employee #1, a subcontractor, performed maintenance on commercial foodservice equipment. He was in the kitchen area of a single-story restaurant, attempting to locate the source of a refrigerant leak in an ice cream storage dipping cabinet. Employee #1 connected a Nitrogen cylinder to the dipping cabinet’s refrigeration system via a hose…...

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