Bryan Haywood

What is an approved self-closing valve?

This week I posted the requirement for transferring a flammable liquid using “gravity”.  This requirement comes from OSHA’s flammable liquid standard… 1910.106(e)(2)(iv)(d) flammable liquids shall be drawn from or transferred into vessels, containers, or portable tanks within a building only through a closed piping system, from safety cans, by means of a device drawing through

EPA RMP GDC citations @ windshield wiper fluid manufacturing facility (Methanol & $197K)

PLEASE NOTE this case is significant in that many facilities in the OSHA arena will EXEMPT their “methanol” from PSM coverage using the “Atmospheric Storage Tank” exemption (e.g. 1910.119(a)(1)(ii)(B) or called the “Meer Decision”).  EPA couldn’t care less about this OSHA exemption, as is evident in this case! There is NO EPA RMP exemption for flammable liquids stored

OSHA clarifies the 6-month testing frequency of Rubber Insulating Electrical Gloves (1910.137)

One of the more common deficiencies that we find in our audits is the lack of electrical gloves testing.  1910.137, Table I-5 establishes the testing frequency for these gloves; however, the confusion comes with the “footnote” which states… If the insulating equipment has been electrically tested but not issued for service, the insulating equipment may not

EPA RMP citations @ LPG and Butane facility

Respondent owns and operates a liquefied petroleum gas plant which handled and handles a maximum of approximately 3,548,000 pounds of propane and 761,400 pounds of butane at the Facility. EPA conducted an inspection of the Facility on October 17, 2018 to determine Respondent’s compliance with CAA Section 112(r)(l) and (7) and the Chemical Accident Prevention

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