Bryan Haywood

EPA GDC RMP citations @ cold storage facility (NH3 & $40K)

This CAFO both initiates and resolves an administrative action for the assessment of monetary penalties, pursuant to Section 113(d) of the CAA. As discussed below, the CAFO resolves the following CAA violations that Complainant alleges occurred in connection with Respondent ‘s storage and handling of anhydrous ammonia at its cold storage and distribution facility: failure […]

What does it mean when we say our facility has coordinated response needs with local emergency planning and response organizations?

While doing some “Pre-Start Up Review” work for a client, I was tasked with reviewing the Emergency Response aspect of the facility’s ability to respond to an NH3 incident.  As part of this review I asked the question… Have we coordinated our emergency response needs with the LEPC and the local FD(s)?  This is a NEW

Confined Spaces: Silent & Invisible Killers (USCG Alert, 4/12/2019)

This is a reminder that despite decades of work by to improve confined space entry by maritime safety organizations, training institutions, and vessel owners/operators, the risks have NOT BEEN ELIMINATED.  This is illustrated by a recent casualty where three (3) persons were asphyxiated while working onboard a laid-up Mobile Offshore Drilling Unit (MODU). Although the investigation is not

OSHA, the IFC, and your Emergency [egress] Lighting

This morning, we had some serious weather pass through the Cincinnati area, and many areas lost power.  Ironically, I was conversing with a client in MI about emergency lighting inspections when the power at the facility where I am this week went out.  Of course, this facility’s emergency lighting activated and worked properly, so employees

Quite Possibly the best ASME B31.3 Cheat Sheet for Anhydrous Ammonia (MN-Dept of Ag)

9/2020 UPDATE:  I have contacted the Minnesota Department of Agriculture, Pesticide & Fertilizer Management Division regarding a statement on this 2-page “Cheat Sheet” regarding their apparent requirement that Hydrosrtatic RVs be put on NH3 vapor piping and vapor hoses.  This is how it is presented: Hydrostats must be installed in each section of liquid and

OSHA further clarifies in-plant labeling vs. “shipped containers” labeling under the GHS (1910.1200(f)(1) 1910.1200(f)(6) 1910.1200(f)(7)

Background: Your company has an internal communication method to communicate the identity of hazardous chemicals transported on company vehicles from one location to another location within the same building (intra-plant). This method uses words, pictures, and/or product identification number, NFPA, HMIS, or DOT identifiers. The company also uses this communication method when transporting hazardous chemicals

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