Bryan Haywood

OSHA PRCS Citations @ asphalt plant ($89K)

OSHA has cited an asphalt paving contractor after an employee suffered fatal injuries after being pulled into an unguarded slat/drag conveyor at the company’s North Platte, Nebraska, asphalt plant. OSHA proposed penalties totaling $89,032.  OSHA cited the company for seven serious violations of machine guarding, lockout/tagout and permit-required confined space standards, including failing to develop a…...

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EPA RMP citations @ meat processing facility (NH3 & $47K)

The business has operated a meat processing facility since 2013. The Facility uses 30,000 pounds of anhydrous ammonia in its refrigeration system at the Facility. EPA alleges the facility failed to ensure that its anhydrous ammonia refrigeration equipment complied with recognized and generally accepted good engineering practices, in violation of Section 112(r)(7) of the CAA…...

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EPA RMP citations @ seafood plant (NH3 & $10K)

NOTE:  Another EPA RMP inspection where they took issue with the use of “ribbons” used in lieu of lockout locks!   EPA has determined that Respondent violated the Risk Management Program (RMP) regulations promulgated at 40 C.F.R. Part 68 under Section 112(r) of the Clean Air Act (CAA), as noted on the enclosed Risk Management…...

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Corrosion Under Insulation (CUI) and just a tad bit of thickness loss

If you stay in process safety long enough you will see some scary stuff!  It seems that “piping inspections” are become the norm these days, which after only 27 years of OSHA’s PSM standard being around I guess it is “about damn time!”.  Having grown up in the chemical industry, MI inspections were a way…...

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OSHA’s view on “troubleshooting” with open guards

This week we saw OSHA issue $300K in citations to a MS papermill, of which LOTO was an area that was cited.  One particular situation that caught my eye was the citation regarding “troubleshooting” behind a guard…. (see item (a) below)… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log...

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PRCS Fatality in Tanker Truck due to H2S and HCN exposures

This is one type of situation where (c)(5) could be a means to enter a PRCS and OSHA agreed and issued some (c)(5) citations. At 8:15 p.m. on May 25, 2018, Employee #1 was power washing the outside of the semi-truck tanker trailer. The employee entered the tanker trailer to wash the inside and was…...

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REPORT ALL INCIDENTS… regardless of how small you think it is

At 11:00 a.m. on June 1, 2018, an employee was transferring a chemical degreaser containing 1-5% caustic sodium hydroxide, from a 5-gallon jug into a small bottle. The chemical spilled onto the employee’s left hand and pants. The employee took off his pants, wiped his legs with wet cloths, and changed clothes. However, the employee…...

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PRCS Engulfment fatality in Sawdust Bag-house

At 2:30 p.m. on March 10, 2018, Employee #1 was using an aerial lift to gain access to an emergency access panel on a dust collection silo that was 25 feet above the ground. From the aerial lift, Employee #1 was using a two-inch water hose to spray water into the silo to remove the…...

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Fatal Flash Fire inside PRCS (Construction PRCS)

This case is a perfect example of how OSHA will use the newer Construction Confined Space Standard in a general industry workplace based on the actual work being performed. At 3:30 p.m. on May 3, 2017, Employee #1 was spray coating the inside of a 6 foot by 23-foot stainless steel tank, using Plasite 7133,…...

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Employee enters PRCS to retrieve a bag liner that had fallen into the space (Oxygen Deficiency Fatality)

On May 5, 2018, Employee #1 was retrieving a plastic liner bag from a chemical container that had fallen into Reactor CP-2; a confined space. The permitting process, including air monitoring and setting up of ventilation, had not been conducted. As Employee #1 descended a ladder to access the reactor, he passed out at the…...

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Sanitation Employee injured by Anhydrous Ammonia (Never saw this one coming)

At 4:00 p.m. on January 5, 2018, Employee #1, employed by an industrial cleaning company, was working at a multiemployer project. He was working from an 8-foot stepladder, Werner Fiberglass 300-pound capacity P/N 100521-127 Model Number T6208 Mk 4. He was 2 feet above the ground and monitoring and adding water as necessary to evaporator…...

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Lockout Alert! Disconnect on Doors

Recently I came across a situation at a facility that is NOT all that uncommon and we need to spread the word.  It involves using an electrical disconnect on an electrical panel door.  As you will see in the STAGED video (NO one was at risk in the video) that I turned the disconnect off,…...

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