Bryan Haywood

Chemical Processes, LOTO, and three (3) program buckets (Simple, Traditional, Complex)

Way back in April 2016, the OSHRC published a decision that settled the argument about LOTO procedures for “specific equipment/machines” and what they must contain.  This important decision helped settle a lot of scuttlebutt about how LOTO gets managed in “complex” situations.  I like to explain to clients that LOTO in a chemical process is…...

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Process Safety Training – April 2-6, 2018

A local client has requested another 40-hr Process Safety Management course and we have scheduled it for the first week of April 2018.  The course will be at: Sugar Creek Packing Company 2600 N James H McGee Blvd Dayton, OH 45417 NOTE: this is the same location that held the “Safety for PSM/RMP Managers” course. Time: …...

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EPA RMP citations @ winery (NH3, with 284 pound release; $330K)

On September 11, 2012, a Facility experienced a 284-pound release of anhydrous ammonia from its ammonia refrigeration system. The incident occurred when a worker attempted to defrost an ammonia chiller and opened the oil valve instead of the hot gas valve, causing ammonia to release into the environment. As a result of the release, an…...

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Safety culture or an amazingly obident workforce?

We hear the phrase “safety culture” being tossed around in today’s management like it is some measurable object or goal.  This, in its own right, shows the vast lack of understanding of what a safety culture is.  My first boss, who I will always praise, was all about his employees.  He wanted the very best…...

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2018 Video of the Week #6 (Unsafe Behaviors are now a “team building” activity)

Just when we think we have seen the limits of human unsafe behaviors, we are reminded that humans are capable of reaching new heights of UNSAFE behaviors when they work as a team!… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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2018 Photo of the Week #6 (Trench Accident – why they continue)

As the tragic trenching accidents continue to stack up, this week’s photo shows us that merely providing a protective device(s) is ONLY HALF the challenge.  As we can see, Trenching also creates fall hazards as well…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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ASME B31.3 Pressure Testing and Leak Testing Requirements for Process Piping

Last year I broke down the pressure and leak test requirements found in ASME B31.5 for those of you in the Ammonia Refrigeration industry, and at the time, I promised I would do the same for those of you that use ASME B31.3 in all the other process industries. And as I got busy with…...

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LOTO, “Clam Shells”, OSHA, and “substantial”

To follow up on the post from yesterday regarding the use of these “lockout devices”, I was reminded by many of you in the same camp as me, that these devices are also highly questionable when we look at their ability to meet the “substantial“ requirement.  These safety pros all agreed that the use of…...

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EPA RMP citations @ dairy (NH3, with 1,290 pound release; $22K for the release; $135K for RMP)

The Respondent owns a milk production facility and according to the U.S. Census data from 2010, several thousand people live near the Facility. The Facility has been in use as a dairy since 1886, and at the time of EPA’s inspection, included a milk production site, office space, chemical storage, warehousing, and production areas. The Facility…...

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Do “clam shells” comply with OSHA’s definition of “Lockout Device”

UPFRONT DISCLAIMER:  I am not suggesting you throw out any of your LOTO devices or change your practices.  This is NOT advice, merely an attempt to demonstrate how some companies go above and beyond OSHA minimums. In my days working in the chemical industries, I had the pleasure of working with some of the finest plant managers,…...

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Human Factors and Process Valves

The topic of human factors (HF) is often times misunderstood and sadly sometimes not even a thought during a Process Design/Engineering Review or a Process Hazards Analysis.  Now I know some of you will scream… “we are not a refinery” so there is no need for us to go to this level in our efforts…...

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D.C. Circuit Court Sets Oral Arguments for Challenging EPA’s delay of the RMP Amendments

The U.S. Court of Appeals for the District of Columbia has set the date for “oral arguments” (Friday, March 16, 2018, 9:30 A.M. USCA Courtroom 31) challenging EPA’s delay of the Risk Management Plan (RMP) Amendments.  The case is 17-1155 Air Alliance Houston, et al., v. EPA and E. Scott Pruitt…. Membership Required You must be a...

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