Bryan Haywood

Canada’s Ammonia Refrigeration staffing requirements (Public Occupancies)

Canada has an interesting requirement for their NH3 refrigeration plants that operate within structures where the general public could be exposed to the NH3.  Since the promulgation of OSHA’s PSM standards in 1992, OSHA has shied away from even mentioning “staffing” for a covered process.  In the USA, we have plants that run 24/7/365 without…...

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Line Break gone BAD (Chlorine)

We have yet another failure of enormous proportions.  When two workers, one of which is a Supervisor, are opening a liquid chlorine line and they have on supplied-air respirators without the regulator attached to the facepiece we have entered into the Twilight Zone.   WorksafeBC has levied a $318,707 fine against the city’s water-treatment plant for:…...

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When we fail @ Hot Work Safety (Video of Designated HW area)

Whether we’re in process safety or just good ole fashioned occupational safety and health, the act of performing hot work (welding to the layperson – my feeble attempt at some Dumb and Dumber humor) can be one of the most dangerous task workers can perform.  Add in the fact the hot work is done within…...

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Does a manufacturer’s maintenance instruction over-ride OSHA’s “minor servicing” exception?

We have a machine and this machine has a couple of tasks that have been deemed “minor servicing”.  As we walk by we see a worker in the machine and no LOTO in place so of course we stop and ask about the situation.  We are told the task being done, “XXXXXXXX”, is indeed a…...

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When bollards look good, but fail miserably

Bollards – a safety engineer’s best friend and a facility engineer’s worst nightmare.  I am not quite sure how we lost our way in such a simple design for such a significant safeguard.  But the International Fire Code (IFC) since the early 1990’s when I began using it has remained consistent in the design of…...

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Understanding Nitrogen Hazards – It is NOT a “toxic hazard” (OSHA GHS)

Last year I was attending some continuing education for my hazardous materials work.  The instructor was outstanding until he went on his tirade against Nitrogen (N2).  He was factually correct when he stated that N2 was a leading killer within confined spaces, but he went off the rails when he tried to convince me that…...

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EPA RMP citations @ refrigerated warehouse and storage facilities (NH3 & $53K w/ $112K SEP)

Respondent is a business that owns and operates two (2) refrigerated warehouse and storage facilities located in Nebraska and Minnesota. The Nebraska facility is located in EPA Region 7 and the Minnesota facility is located in EPA Region 5. Information gathered during the EPA inspection revealed that Respondent had greater than 10,000 pounds of anhydrous…...

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CSB’s Accidental Release Reporting

Here is an initial look at the rule, signed by the CSB Interim Executive today. The final rule requires an owner or operator of a stationary source to submit an accidental release report to the CSB. The rule describes when to file a report of an accidental release and the required content of such a…...

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Permit-Required Confined Space Program (w/ Construction requirements)

Attached is the written program for General Industry facilities which incorporate OSHA’s newer Confined Spaces in Construction requirements.  It is my recommendation that we UPDATE our written program that was based on the older 1910.146 standard to include all the improvements in 1926.1201 – .1213.  We should also understand that even though our facility may…...

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No Procedure for Requesting RMP Five-Year Review Extension

The Risk Management Program (RMP) regulations require the owner or operator of a stationary source to revise and update the source’s RMP at least once every five years from the date of its initial submission or most recent full update (§68.190(b)).  Is there a procedure for obtaining an extension to complete the five-year review? … Membership...

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Types of Information Relevant for Response Planning

The Risk Management Program emergency response coordination activities require the owner and operator of a stationary source to provide to the local emergency planning and response organizations: the stationary source’s emergency response plan if one exists; emergency action plan; updated emergency contact information; and any other information that local emergency planning and response organizations identify…...

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Time Frame to Submit RMP Emergency Contact Information Changes

How much time does the owner or operator of a stationary source have to submit a correction to a Risk Management Plan when the emergency contact information changes? The Risk Management Plan (RMP) regulations require an owner or operator of a stationary source to correct their RMP within one month (i.e., 30 days) of any…...

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