Bryan Haywood

Fuel vaults are PRCS’s (OSHA Fatality Case File)

A few weeks ago we were debating in my FaceBook Group about these vaults being a PRCS.  The picture in question (shown to the left – full scale in the article) had a working platform just a little more than 4′ down inside the vault, but the fixed ladder went all the way down to…...

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Water Valve Pits are Permit-Required Confined Spaces (1926 Subpart AA – Confined Spaces in Construction)

We go all the way back to 1996 and OSHA issued a Hazard Information Bulletin regarding Asphyxiation Hazard in Pits: Potential Confined Space Problem.  Fast forward 23 years later and we have this:  At 2:23 p.m. on July 8, 2019, a worker employed by a utilities construction company was working in an underground vault. He…...

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EPA RMP citations @ refrigerated food processing facility (NH3 & $10K)

This inspection was for the purpose of determining compliance with Section 112(r)(7) accidental release prevention requirements of the Clean Air Act, as amended in 1990. The scope of this Inspection may include, but is not limited to: reviewing and obtaining copies of documents and records Interviews and taking of statements reviewing of chemical storage, handling,…...

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EPA RMP citations @ poultry processing plants (NH3 & $106K w/ $398K SEP)

Respondent is a Poultry Processor doing business in the States of Alabama, Arkansas, and Mississippi. On November 10, 2016, the EPA issued to Respondent a Notice of Concern letter which informed the Respondent that EPA had concerns that the Respondent was not in compliance with the CAA Section 112(r). The Respondent and EPA met on…...

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Smoke detectors SAVE LIVES!

On Sunday, February 23rd at approximately 12:34 AM, the Joplin Fire Department responded to a reported structure fire with people possibly still inside. A Joplin Police Department officer in the neighborhood patroling arrived at the same time we were getting the call and was able to assist all occupants out of the structure through the…...

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EPA EPCRA/CERCLA citations for two NH3 Releases from refrigeration process

This is a lesson in reporting your releases! Two releases of anhydrous ammonia from a refrigeration process result in $150,000 in fines ($75K for EPCRA and $75K for CERCLA) and a $425,000 SEP to install detectors and emergency shutdown systems. The Complaint alleges that: Respondent violated Section 103(a) of the Comprehensive Environmental Response, Compensation, and…...

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EPA RMP citations @ chemical distributor (Cl2 & SO2 and $100K)

Respondent owns a chemical supply outlet where chlorine was present in a process above the 2,500 pounds TQ, and sulfur dioxide was in a present in a process above the 5,000 pounds TQ from at least March 16, 2010.  Respondent was required to submit and have in place an RMP for the facility. Under 40…...

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Pressure Test gone bad (Pneumatic)

On March 2, 2012 Employee #1 of a food processing company was standing-by while a contractor was pressure testing a newly installed compressed air unit. The pipe exploded when the contractor tried to tighten a joint on a leaking pipe and employee #1 was struck in the head by a two-inch steel pipe…. Membership Required...

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Pneumatic pressure testing of plant air piping system gone bad (Fatality and Injury)

We have discussed “pressure testing” and the hazards associated with these required tests many times.  This is an example of what can go wrong when doing these tests with a compressed gas vs. hydrostatically!  A mechanical contractor was increasing the pressure into the 4-inch compressed air line from approximately 125psi to the TEST PRESSURE of…...

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OSHA issues Willful for Respirator use associated with entering a PRCS

OSHA has dined a Delaware Rail Car Tank Cleaning And Repair Facility $371,276 for Safety and Health Hazards.  This same company, different location, was cited last year after a PRCS fatality inside a Rail Car (PRCS fatality cleaning a railcar (Oxygen Deficient and $551K): Membership Content).   This inspection was initiated due to a complaint, but surely…...

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Isolating pneumatic energy sources and verifying a ZES

Earlier today I posted a recent OSHA citation where a facility was cited for not having procedures regarding the means to isolate and verify ZES for pneumatic energy sources (i.e. plant air).  For some reason, on nearly all of my LOTO projects I find that air sources are a bastardized source of energy when it…...

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OSHA cites employer for LOTO issues (Magnitudes, Means to verify ZES)

This OSHA citation involves items other than LOTO. Still, the LOTO citations caught my eye precisely because the equipment-specific procedures did NOT state how pneumatic sources (e.g., air) were to be verified at a Zero Energy State (ZES).  The means to verify a ZES is a critical step in LOTO, and far too often, the…...

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