Bryan Haywood

Ohio Environmental Protection Agency’s Business Impact Analysis on OAC Chapter 3745-104, “Accidental Releases Prevention Program” (RMP)

/ Chemical Process Safety (PSM/RMP), Free /

The State of Ohio’s EPA performed “Business Impact Analysis” on their version of the Risk Management Plan, as part of an Ohio requirement.  The Ohio EPA RMP rules, which are consistent with federal requirements, became effective August 13, 1999. Ohio EPA received “Delegation of Authority” for the Accidental Release Prevention Program, or Risk Management Plan (RMP) program, effective […]

EPA RMP citations @ agricultural chemical manufacturing facility (CH4S, C3H9N, C2H7N, NH3 & $72K )

/ Free, PSM and RMP Citations/Analysis /

Respondent owns and operates an agricultural chemical manufacturing facility. On or about August 18-19, 2015, EPA conducted an inspection of Respondent’s Facility to determine compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68. Information gathered during the EPA inspection revealed that Respondent had greater than 10,000 pounds of methyl mercaptan in a

FM Global’s NEW Data Sheet shares Loss Histories related to Ammonia Refrigeration Processes

/ Chemical Process Safety (PSM/RMP), Free /

FM Global, my absolute favorite source of RELIABLE and FREE safety information has published a new Data Sheet titled 7-13 Mechanical Refrigeration.  This data sheet and hundreds more are available for FREE (after a very brief registration) to anyone.  A truly MUST have for any safety professional working in an industrial environment!  In their new Data Sheet, 7-13 Mechanical

Ammonia release study from INERIS

/ Free, Hazardous Materials /

The French National Institute for Industrial Environment and Risks (INERIS) conducted a study to examine how anhydrous ammonia would behave under a number of different release sceanrios. The main aims of this study were: to analyse the risks represented by facilities using quantities of ammonia of up to a few dozen tonnes to complete knowledge on the

Using the “energy isolation plan” worksheet to meet specific LOTO procedures

/ Free, Lockout Tagout /

OSHA’s Lockout/Tagout (LOTO) standard is pretty clear… ALL servicing and maintenance activities that require the control of hazardous energy require a machine/equipment-specific written procedure. (e.g. 1910.147(c)(4) 1910.147(c)(4)(i) Procedures shall be developed, documented and utilized for the control of potentially hazardous energy when employees are engaged in the activities covered by this section. So does this

42 Incidents (1/29 – 2/10/2018)

/ Free, Incident Alerts (2011 - 2018) /

Industrial LOTO FATALITYHawkins worker killed at MIS Inc. plant in Phipps Bend (worker, 34, was killed after getting stuck in a large piece of equipment while reportedly trying to dislodge a part that had gotten stuck – as soon as the part was dislodged, the door closed on the worker – death would have been

Documenting the “isolation” of a Permit-Required Confined Space

/ Chemical Process Safety (PSM/RMP), Free, Lockout Tagout, OSHA Compliance, Safety Management System /

To continue with my series of LOTO articles this month, I want to discuss how 1910.147 plays into our efforts to enter a Permit-Required Confined Space (PRCS).  Way too many PRCS entry permits have the basic check-the-box statement “All energy sources isolated – YES/NO.”  What the heck is that supposed to meet?  Do our “machine

Is a “Lockout device” more than a Lockout Lock?

/ Free, Lockout Tagout /

As the debate continues about using “clamshells” as a lockout device, our behind-the-scenes discussions continue regarding OSHA’s use of the term “Substantial”. The discussion was so good I asked if I could summarize and post it to keep the discussions going. So once again, here is OSHA’s definition of a “Lockout device”: A device that

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