Bryan Haywood

A new grade of anhydrous ammonia fertilizer means an MOC, PSSR, etc.

This month Koch Agronomic Services (KAS) announced they have developed a “nitrification inhibitor” for their anhydrous ammonia (NH3) fertilizer that will significantly improve nitrogen use efficiency (NUE) to increase crop output while minimizing environmental losses.  This is great news for all of us; however, for those at the facilities where this new grade of NH3 is being…...

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Using codes/standards from foreign countries to improve process safety

Ontario’s Engineering Data Sheet 4-04: Anhydrous Ammonia is an excellent source of reliable safety information for the design of and practice of safely handling anhydrous ammonia.  It is another example of how we can use information from other agencies around the world to better design, build, operate and maintain processes handling/storing/processing highly hazardous chemicals…. Membership...

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OSHA wins Silica Rule Appeal

Industry petitioned for review of five issues: whether substantial evidence supports OSHA’s finding that limiting workers’ silica exposure to the level set by the Rule reduces a significant risk of material health impairment; whether substantial evidence supports OSHA’s finding that the Rule is technologically feasible for the foundry, hydraulic fracturing, and construction industries; whether substantial…...

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2017 Video of the Week #52 (Above the UEL)

I have always wanted to do this kind of real-life demo/experiment during my FLAG training sessions but in today’s litigious environment I have always feared what could go wrong.  Step in some brothers in the fire service and we now have a video showing why being in an atmosphere ABOVE the Upper Explosive Limit (UEL) is extremely dangerous.  The use…...

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Annual SOP(s) review and training

As this year comes to a close, I was reminded by a FaceBook post of a common misconception regarding 1910.119(f)(3), which is actually two (2) separate requirements/actions stated in a single paragraph of the standard.  The standard states: 1910.119(f)(3) The operating procedures shall be reviewed as often as necessary to assure that they reflect current operating practice, including…...

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The safety irony award of 2017

Just in time to win this year’s Safety Irony Award, the Philidelphia City Council passed a bill this week that calls for the city’s Department of Licenses and Inspections to develop rules for the “USE OR REMOVAL” of the bullet-proof barriers by January of 2021.  This news came on the heels of OSHA’s announcement this week that “Workplace violence…...

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Combustible Dust and EPCRA 311/312 reporting

For those who deal with emergency planning and response know all too well about EPCRA’s Tier Sheets, most notably Tier II sheets that facilities submit annually so as to inform the emergency response community of their hazardous materials and extremely hazardous substances on site.  These Tier sheets have been around since 1986 and are still a…...

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Correcting RMP with new emergency contact information

As I have said before, one of EPA’s most cited RMP matters is the lack of “updating the RMP with emergency contact information within a month of the change“.  But today, the EPA offered some insight for those who may not have an emergency contact assigned within the month of the change.  For me, there are…...

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Respiratory protection may have exacerbated a pre-existing medical condition in CS fatality

On February 3, 2017, at approximately 5:57 p.m. an employee was working in the crawl space of Tower B to unclog food sink drains underneath the facility’s kitchen. Workers were working in a confined space in Mechanical Room Number 5. They were tasked to unclog four food drains, which were located 50 to 60 feet…...

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MARPLOT 5.1.1 is now available for download (December 2017)

What’s changed in MARPLOT 5.1.1? Made improvements to the auto-upgrade process to resolve rare issues some users experienced when upgrading to 5.1 Modified new layer creation process so that layers default to Individual Graphics Mode Updated U.S. Boundaries layers to 2017 data Enhanced threat zone information display in ALOHA popup notes Made improvements to the…...

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OSHA issues PSM Hot Work Citations after Triple Fatality @ Paper Mill

On February 8, 2017, @ 11:15 a.m.three (3) contractors were climbing down from an elevated pipe rack. As they were climbing down, the stainless steel “Foul Condensate” tank exploded, striking the workers and tossing their bodies 200 yards from the explosion. All three workers were killed.  OSHA issues five (5) Serious Citations releated to Hot…...

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