Bryan Haywood

Ammonia ship transfer release (Government of Western Australia)

On 21 July 2018, a major release of ammonia gas occurred at a Western Australian port. As part of standard operation, an ammonia tanker vessel was supplying anhydrous ammonia to a process plant. Following the completion of liquid ammonia unloading, purging of the loading arm and pipework was commenced with ammonia gas supplied by the…...

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OSHRC affirms Willful and Repeat LOTO citations, Egress, and PPE matters

Last week I shared this OSHRC case as a “cultural example” of how a management team tries to move on from a Safety Manager leaving the facility and their duties were passed on to the HR manager who had no S&H experience or training, so they hire an outside safety consultant to help with LOTO…...

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OSHRC affirms Willful and Repeat LOTO citations, Egress, and PPE matters

Last week I shared this OSHRC case as a “cultural example” of how a management team tries to move on from a Safety Manager leaving the facility and their duties were passed on to the HR manager who had no S&H experience or training, so they hire an outside safety consultant to help with LOTO…...

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EPA RMP citations @ gluten, starch, and alcohol production facility AFTER a WRONG CHEMICAL – WRONG TANK incident caused a Cl2 release (Propylene oxide & $250K)

Lesson’s learned:  A WRONG CHEMICAL – WRONG TANK incident produced a chlorine release and brought EPA to the facility.  The EPA inspection does not appear to have looked at the Cl2 incident, but rather stayed focused on the propylene oxide process – their “covered process”.  As well, in March of this year both the facility…...

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EPA RMP citations @ gluten, starch, and alcohol production facility AFTER a WRONG CHEMICAL – WRONG TANK incident caused a Cl2 release (Propylene oxide & $250K)

Lesson’s learned:  A WRONG CHEMICAL – WRONG TANK incident produced a chlorine release and brought EPA to the facility.  The EPA inspection does not appear to have looked at the Cl2 incident, but rather stayed focused on the propylene oxide process – their “covered process”.  As well, in March of this year both the facility…...

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EPA RMP Program 2 citations @ agriculture retail facility (NH3 & $45K, w/ $8K SEP))

Respondent operated an agriculture retail facility and receives, stores, and sells anhydrous ammonia. On or about June 19, 2018, representatives of the EPA conducted an inspection of Respondent’s Facility to determine compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68. Information gathered during the EPA inspection revealed that the facility had ammonia…...

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EPA RMP Program 2 citations @ agriculture retail facility (NH3 & $45K, w/ $8K SEP))

Respondent operated an agriculture retail facility and receives, stores, and sells anhydrous ammonia. On or about June 19, 2018, representatives of the EPA conducted an inspection of Respondent’s Facility to determine compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68. Information gathered during the EPA inspection revealed that the facility had ammonia…...

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NH3 liquid into water reaction

A few years ago I posted a fatal incident involving unloading NH3.  The driver made a valving error and left the liquid bleed valve to a plastic tote open while he was transferring liquid NH3 to the storage tank.  He was standing ~6-10′ from the tote when it violently ruptured when the liquid NH3 entered…...

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NH3 liquid into water reaction

A few years ago I posted a fatal incident involving unloading NH3.  The driver made a valving error and left the liquid bleed valve to a plastic tote open while he was transferring liquid NH3 to the storage tank.  He was standing ~6-10′ from the tote when it violently ruptured when the liquid NH3 entered…...

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Emergency Drill Done Right… Ask yourself

Many of us may not be able to understand the commentary unless you speak Spanish/Portuguese, but watch how this drill is managed!  For those who are “Incident Commanders” watch all the different functions that are being managed simultaneously in the HOT and WARM zones!  And remember, this is a “drill” – in a real incident…...

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Emergency Drill Done Right… Ask yourself

Many of us may not be able to understand the commentary unless you speak Spanish/Portuguese, but watch how this drill is managed!  For those who are “Incident Commanders” watch all the different functions that are being managed simultaneously in the HOT and WARM zones!  And remember, this is a “drill” – in a real incident…...

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2019 OSHA’s Process Safety Management (1910.119) activity by Industry Sectors

Here is a look at OSHA’s Process Safety Management (1910.119) compliance activity during the period of October 2018 through September 2019. As you can see, OSHA issued 263 citations from 76 inspections for a total of $2,732,232 in fines.  Here is a quick breakdown of activity:… Membership Required You must be a member to access this...

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