Bryan Haywood

Using a Voltmeter is ENERGIZED electrical work!

I am not an electrician, I don’t even consider myself a Qualified Electrical Worker, but I do know Electrical Safety-Related Work Practices (and I stayed at a Holiday Inn Express last week). I do not do a lot of electrical safety training (except for existing clients), but it seems that every time I have done…...

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Reclassifying a PRCS to a Non-PRCS is more than just locking out energy sources!

Too many safety professionals still to this day think that to reclassify a Permit-Required Confined Space (PRCS) is simply to lock out all the energy sources that made the space a PRCS.  In August of last year, I posted a story where I asked the 30,000 members of the SAFTENG network if an enclosed palletizer…...

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EPA EPCRA/CERCLA citations for two (2) Ammonia releases ($82K)

“Minor” LOPC events that are allowed to continue over a weekend can be a COSTLY MISTAKE!  Any LOPC event MUST be reported ASAP to that it can be addressed, regardless of how “minor” it may be considered!  We have to keep our HHC/EHS’s in their PRIMARY CONTAINMENT and when we have a failure that lets…...

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OSHA PSM Citations @ Refinery (HF Acid & $132K)

OSHA has cited a refinery for serious violations of safety and health hazards related to process safety management (PSM) following a fire and subsequent explosions at the company’s Refinery Complex in June 2019. The company faces $132,600 in penalties.  OSHA’s inspection found deficiencies in the refinery’s PSM program, including failing to establish or implement written…...

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Line Break gone bad (Natural Gas Condensate w/ flash fire)

Opening a Natural Gas Condensate line with a battery-operated drill inside a compressor building is ASKING for trouble.  Basic HAZLOC work practices include using INTRINSICALLY SAFE tools that are APPROVED for the HAZLOC, which has been an OSHA requirement since 1981… 1910.307(c) Electrical installations. Equipment, wiring methods, and installations of equipment in hazardous (classified) locations…...

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EPA RMP Program 2 citations @ agriculture retail facility (NH3 & $71K, w/ $55K SEP)

Respondent is the owner and operator of a facility that had greater than 10,000 pounds of anhydrous ammonia in a process at each of its facilities. From the time Respondent first had onsite greater than 10,000 pounds of anhydrous ammonia in a process, Respondent was subject to the requirements of 40 C.F.R. Part 68 because…...

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EPA RMP citations @ chemical supply outlet (Cl2 and SO2 & $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 has two (2) program 3 processes: a chlorine cylinder storage process, and a sulfur dioxide…...

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Human Errors and lack of verification leads to Hydrogen Tube Trailer Fire (2K evacuated & $175K in damages)

The NTSB has determined that the probable cause of the 2018 Hydrogen tube trailer fire in California was human errors made by two non-related personnel from two different companies with both workers making errors on the pressure relief system: REQUALIFICATION TECHNICIAN’S installation of an INCORRECTLY RATED PRESSURE RELIEF DEVICE in cylinder No. 14, which actuated…...

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Inadvertent Opening of Valve Causes Injury (Safety Alert)

Remember that project where we installed new XXXXXXX and to save money we did not remove the old XXXXX and just piped around it?  We always thought that the old piping and valves were not a hazard, well think again… On May 20, 2019, an offshore oil and gas worker was conducting daily rounds, which…...

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Flammable Liquids per Control Area

One part of managing flammable liquids is minimizing fuel load in the event there is a fire.  Both state codes and OSHA utilize what is called “maximum allowable quantity per control area“.  This practice is based on the “degree of hazard” or as OSHA calls them today “Hazard Category” of the flammable liquid or gas…...

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Did the State of Georgia make NH3 a “permitted HAZMAT” in 2019?

If you’re in the ammonia fertilizer business in the State of Georgia (GA) this may be of interest to you.  Although I should point out that the Code language did NOT exclude ammonia held as a refrigerant.  On November 25, 2019, the Administrative Procedure Division of the Office of the Insurance and Safety Fire Commissioner…...

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Safety Culture is not the responsibility of the safety team

Over the past decade, we saw a huge swing away from safety being a technical field to one that is more hugs and kisses.  Last year, we even saw the number one organization for safety professionals change their name from Safety Engineers to Safety Professionals.  Along with the name change came a change to topics…...

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