Bryan Haywood

Line Break gone Bad (Steam & $75K)

Another tragic ending to a “Line Break” gone bad. This one involved opening a flange on a steam line in an attempt to “bleed off” the steam by loosening flange bolts. IT DID NOT GO AS PLANNED, and two workers perished with 70% burns! At 6:52 p.m. on August 10, 2020, two (2) employees (30)…...

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Flanged Joint Assembly Records (ASME PCC-1)

As we have discussed here for years, “flanged joints” are usually MORE difficult to manage than are welded connections. However, somehow the rumor got started that flanged connections can be done by “Billy Joe Jim Bob.” Nothing could be further from the truth! And guess which connections most often leak? Yep, flanged connections. There are…...

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Large-scale (10K pound) Cl2 Release in Freeport, TX

Betting this was just under 10 pounds. That’s a RQ joke as the RQ for Cl2 is 10 pounds – CLEARLY we have exceeded that in this event. (But you never know!) All jokes aside, this is a big one. People wanting to know why it’s taking so long to get an “all clear” 2-hrs…...

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EPA EPCRA/CERCLA citations ($65K) for 350 pound NH3 release from refrigeration process

Respondent produced, used, or stored ammonia at the Facility and released a reportable quantity of an EHS, ammonia. On or about August 31, 2022, a “release,” as that term is defined by Section 329(8) of EPCRA, of ammonia in excess of 100 pounds occurred at the Facility (the release). As a result of the information…...

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Fire Captain falsified Fit-Test Records and is facing charges

A 45-year-old senior fire captain is facing charges after authorities say he improperly conducted respirator fit tests for firefighters and lied about it. He is charged with forgery and tampering with records, the County Prosecutor’s Office said Friday. He signed reports stating the tests had been completed when they had not been finished between Jan…....

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EPA RMP Citations (NH3 & $105K)

Respondent is the owner and/or operator of the Facility, which operates a chemical storage and distribution facility. The respondent had on-site storage for 50,000 pounds of cyclohexylamine, 1,800,000 pounds of chlorine, 1,500,000 pounds of sulfur dioxide (anhydrous), 265,000 pounds of ammonia (anhydrous), 350,000 pounds of ammonia (concentration 20% or greater), and 17,000 pounds of hydrofluoric…...

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Learning Human Factor mistakes from others

The PSM standard requires the employer’s PHA team to evaluate human factors during its process hazard analysis. CCPS defines human factors as “a common term given to the widely-recognized discipline of addressing interactions in the work environment between people, a facility, and its management systems.” The basic principle of assessing human factors is to determine…...

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Learning MOC mistakes from others

The Management of Change (MOC) section of the PSM standard requires the employer to implement written procedures for managing changes (except for replacements in kind) to processes involving chemicals, technology, equipment, procedures, and changes to facilities that affect a covered process. The MOC procedure requires descriptions of the technical basis for the change, impact on…...

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Learning MI mistakes from others

OSHA has identified the following mistakes found at PSM facilities nationwide. These mistakes were identified at refineries; however, almost all can be found within any PSM-covered process. I have revised OSHA’s wording so that we can ALL learn from these mistakes. PLEASE do not fall for the old trap of “Bryan, we are not a…...

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Safety Pays Individual Injury Estimator

Employers can use the Safety Pays Individual Injury Estimator to assess the impact of occupational injuries and illnesses on their profitability. This program uses a company’s profit margin, the average costs of an injury or illness, and an indirect cost multiplier to project the amount of sales a company would need to generate to cover…...

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Standards Referenced in OSHA Proposed Rule 29 CFR 1910.156 (Emergency Response)

The following NFPA and ANSI standards, in whole or in part, are to be incorporated by reference into proposed rule 1910.156, per 29 CFR 1910.6. See 29 CFR 1910.6(a)(1). Provisions in the proposed standard are drawn from, or consistent with, the following NFPA standards, but these standards are not proposed to be incorporated by reference:…...

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The saga of the bypassed safety interlock

This unfortunate event is the result of the same failure seen in nearly every industrial facility on the planet… a guarding interlock gets bypassed, and a worker pays an unimaginable price for the failure. Sometimes it’s the worker(s) who bypass the interlock, and other times they are the unknowing victim of the bypass. Here is…...

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