Bryan Haywood

EPA RMP citations @ Water Treatment Plant (Cl2 & $2K)

I usually do not waste time posting the Expedited Settlement Agreements, as these cases are typically minor record-keeping violations with low-dollar amount citations. However, one thing that irks me is how public utilities receive lenient treatment regarding the amount they pay for violating the EPA’s RMP regulations. And to make matters worse, they dare to…...

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EPA RMP Citations @ food facility (NH3 & $135K)

Respondent is the owner and/or operator of a facility that operates an ammonia refrigeration plant with 39,000 pounds of anhydrous ammonia. Respondent has one RMProgram level 3 covered process, which stores or otherwise uses anhydrous ammonia in an amount exceeding its applicable threshold of 10,000 pounds. On July 18, 2023, the EPA conducted an on-site…...

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Application of paraffin wax is usually considered First Aid (OSHA)

The question was asked of OSHA… Whether the use of paraffin wax as a form of topical heat application is considered medical treatment beyond first aid for OSHA recordkeeping purposes?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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EPA RMP/EPCRA citations @ refinery (HF and SO2 & $270K)

Respondent operated a facility that refines petroleum products using a hydrofluoric acid alkylation process. Hydrofluoric Acid is a “regulated toxic substance” listed under CAA Section 112(r)(3), 42 U.S.C. § 7412(r)(3), with a TQ of 1,000 lbs. See 40 C.F.R. § 68.130, Tables 1 and 2. On June 2-3, 2022, EPA performed an inspection of the…...

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Safety Thought of the Week… The answer is the worker (Conklin)

Think of the safety journey as one of the vast improvements. When we first started managing safety, we did it by making and enforcing rules about safety and we got better, much better. Then we started to level out, we plateaued in our performance and needed to do something different. Safety got better and then…...

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How should the standard stair width be measured to comply with §1910.25(c)(4)

OSHA standard at 29 CFR 1910.25(c)(4) applies to places of employment and requires standard stairs to have a minimum width of 22 inches (56 cm) between vertical barriers. OSHA does not consider a handrail to be a vertical barrier or obstruction to that required minimum width…. Membership Required You must be a member to access...

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OSHA answers the common questions regarding LOTO Feasibility and Alternative Methods

Background: You stated that your client must perform service and maintenance tasks that will require power in certain circumstances. Some of the tasks qualify for the minor servicing exception to 29 CFR §1910.147 standard. However, there are other tasks that are considered service and maintenance, but still require power. An example is setting up a machine…...

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EHSs and the EPCRA emergency planning requirements

What is purpose of the list of extremely hazardous substances in regards to the emergency planning requirements of EPCRA? The extremely hazardous substances list and its threshold planning quantities are intended to help communities focus on the substances and facilities of most immediate concern for emergency planning and response.  However, while the list includes many of…...

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Release notification requirements for releases of Aqueous Film Forming Foam (AFFF)

Aqueous Film Forming Foam (AFFF), a substance commonly used by firefighters, contains ethanol, 2-(2-butoxyethoxy) which is categorized as a glycol ether.  Glycol ethers meet the definition of hazardous substance in CERCLA 101(14) because they are hazardous air pollutants pursuant to 112(b) of the Clean Air Act.  In 1990, the Clean Air Amendments added 47 individual…...

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Responsibility for SDS Accuracy (EPCRA)

This once caught my eye after all the issues I have encountered with lame SDSs! Remember, these are the first line of information for responding agencies, and man, have they gone downhill over the years. With all the hype of how the GHS would improve the MSDSs of the old days, it has been a…...

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Spills onto concrete floors inside a building (EPCRA reporting)

A facility has a spill of an extremely hazardous substance in an amount greater than its reportable quantity.  The spill occurs on a concrete floor that is inside a facility building.  Before the spill can be cleaned up, a portion (less than RQ) of the EHS enters the outside atmosphere through the window.  Persons in…...

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