Bryan Haywood

Enforcement of 29 CFR 1910.29(f)(1)(ii)(B) & (f)(1)(iii)(A): Heights of Handrail and Stair Rail Systems

/ Free, OSHA Compliance /

MEMORANDUM FOR: REGIONAL ADMINISTRATORS, STATE PLAN DESIGNEES THROUGH: AMANDA EDENS,Acting Deputy Assistant Secretary FROM: PATRICK J. KAPUST, Acting Director,Directorate of Enforcement Programs SUBJECT: Enforcement of 29 CFR 1910.29(f)(1)(ii)(B) and 1910.29(f)(1)(iii)(A): Heights of Handrail and Stair Rail Systems This memorandum replaces the memorandum issued on June 10, 2019, on this subject, and provides guidance to Compliance […]

Qualifiying your PSM/RMP Contractor is more than OSHA Rates! (high pressure piping contractors)

/ Chemical Process Safety (PSM/RMP), Free /

One of the biggest flaws in the OSHA’s and EPA’s process safety standards is their expectations of how contractors are to be evaluated.  Yes, of course, hiring contractors with good safety programs and good safety performance is CRITICAL, but way too many facilities are only looking at the safety numbers and programs.  And that is

Hierarchy of Hazard Control Analysis (HCA)

/ Chemical Process Safety (PSM/RMP), Free /

Following the August 2012 fire and chemical release at a San Fransico Bay Area refinery, the Governor of CA formed the Interagency Working Group on Refinery Safety to examine ways to improve public and worker safety through enhanced oversight of refineries, and to strengthen emergency preparedness in anticipation of any future incident. The Interagency Working

EPA RMP citations @ brewery (NH3 & $0K)

/ Free, PSM and RMP Citations/Analysis /

Respondent is the owner and/or operator of a Brewery which uses, handles, and/or stores more than a threshold quantity of anhydrous ammonia, a regulated substance, as specified at 40 C.F.R. §§ 68.115 and 68. 130. Pursuant to CAA section 112(r)(7), Respondent is required to prepare and implement a risk management program to detect and prevent

Does the HCS apply to universal waste, which is included within the definition of hazardous waste and subject to 40 CFR 273? (OSHA LOI)

/ Free, OSHA Compliance /

Question 1: Does the HCS apply to universal waste, which is included within the definition of hazardous waste and subject to 40 CFR 273? Response: No. As noted in the background section, per 29 CFR 1910.1200(b)(6)(i), the HCS does not apply to hazardous wastes regulated by the U.S. Environmental Protection Agency (EPA) under the Resource

EPA RMP citations @ refinery (HF & $0K)

/ Free, PSM and RMP Citations/Analysis /

Respondent is the owner and/or operator of an Oil Refinery which uses, handles, and/or stores more than a threshold quantity of Flammable Mixture and Hydrogen fluoride/Hydrofluoric acid, which are regulated substances, as specified at 40 C.F.R. §§ 68.115 and 68.130. The EPA conducted an inspection of the Facility from August 15 to August 18, 2016,

Regional Emphasis Program for Fertilizer Grade Ammonium Nitrate (FGAN) and Agricultural Anhydrous Ammonia Facilities

/ Free, OSHA Compliance /

The intent of this Regional Emphasis Program is to encourage employers to take steps to address hazards, evaluate facilities to determine if the employer complies with all relevant OSHA requirements, and help employers to correct hazards, thereby reducing potential worker injuries, illnesses, and deaths. Region VII OSHA proposes accomplishment through outreach and enforcement activities. Outreach

EPA RMP @ fresh produce storage and distribution facility (NH3 & $30K w/ $105K SEP)

/ Free, PSM and RMP Citations/Analysis /

Respondent owns and operates a fresh produce storage and distribution facility comprised of approximately 35 acres that includes cold room facilities and ice making equipment. An ammonia refrigeration system is used to cool fresh produce while in storage and for shipment at the Facility. On September 13, 2017, EPA performed inspections of the Facility pursuant

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