Bryan Haywood

The OSHRC clarifies “storage” and the fire-barrier requirements when storing oxygen and flammable gas cylinders

/ OSHA Compliance /

Both the construction and general industry standards have identical requirements when it comes to storing oxygen cylinders and flammable gas cylinders. Here is the construction industry requirement: 1926.350(a)(10) Oxygen cylinders in storage shall be separated from fuel-gas cylinders or combustible materials (especially oil or grease), a minimum distance of 20 feet (6.1 m) or by a noncombustible…...

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UPDATE on the 40,000 NH3 release in IL in April 2016

/ Chemical Process Safety (PSM/RMP) /

As we await word of any regulatory action stemming from the catastrophic release of Anhydrous Ammonia from a truck unloading incident in Stewardson, IL, in April 2016, I did come across an interesting tidbit that I feel should be shouted from the mountain tops.  So often, one side of our profession decries OSHA and EPA’s…...

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EPA RMP Program 2 citations @ agriculture chemical distribution facility (NH3 $37K)

/ PSM and RMP Citations/Analysis /

On or about November 2, 2016, representatives of the EPA conducted an inspection (the EPA inspection) of the 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 the Facility had greater than 10,000 pounds of anhydrous ammonia in a process. From…...

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NC-OSHA’s acceptable “Lockout Lock” identification method… would you accept this?

/ Lockout Tagout /

The state of NC has its own OSHA Plan (e.g., State Plan), but they use the Federal OSHA standards as their enforcement tools.  As like most state plans, their website is a buffet of safety materials that are free for the taking.  In fact, I used some of their materials when I was a safety manager in…...

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LOTO Fatality (TN-OSHA)

/ Lockout Tagout /

A 51-year-old female employee was fatally injured when she leaned into a machine and was pinned, resulting in crushing injuries to her head and neck. On the day of the incident, the victim was helping out on windshield #1 line due to low staffing levels resulting from inclement weather. She was to keep the line running and relieve…...

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Explosion Fatality – Flammable Liquid Drum (TN-OSHA Inspection #1184467)

/ Flammable Liquids /

A 43-year-old male employee was fatally injured in an explosion. On the day of the accident, the victim, a trailer mechanic, was working alone repairing a trailer in the maintenance shop of a freight distribution facility. There were no witnesses to the incident, and the building was deemed structurally unsound following the explosion. Through a detailed investigation, and incorporating…...

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OSHA enforcement activity on their 1926 Subpart AA – Confined Spaces in Construction

/ OSHA Compliance /

Last month I posted the annual OSHA enforcement activity regarding 1910.146, as well as I posted an update on the 2-year anniversary of OSHA’s 1926 Subpart AA – Confined Spaces in Construction.  Both posts got a lot of discussions started, but the update on the 2-year anniversary of OSHA’s 1926 Subpart AA – Confined Spaces in Construction and how…...

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Ohio upgrades Hot Work requirements when performing Hot work on flammable and combustible liquid storage tanks

/ Chemical Process Safety (PSM/RMP) /

The state of OH is in the process of updating it’s fire code to the 2015 International Fire Code (IFC).  In doing so, the state is upgrading its Hot Work requirements when performing hot work on flammable and combustible liquid storage tanks.  The proposed code will include a new section, Section 3510 Hot work on flammable and…...

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State of Ohio to require NH3 RV Discharge to be thru a destruction system or have an engineering analysis stating otherwise

/ Chemical Process Safety (PSM/RMP) /

The state of OH is in the process of updating it’s fire code to the 2015 International Fire Code (IFC).  In doing so, the state is upgrading its Mechanical Refrigeration requirements and one of the upgrades may have an impact on future Ammonia Refrigeration processes that have over 6.6 pounds (3 kg) of ammonia refrigerant, which would include almost…...

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Hydrostatic test or Pneumatic Test… which shall I use on my flammable liquid piping?

/ Chemical Process Safety (PSM/RMP) /

The debate rages on in process safety circles as to how one can “pressure test” their piping that was installed using ASME B31 series of RAGAGEPs.  It has always been “the rule” that we use the hydrostatic method UNLESS this method would cause a hazard or purity concern; however, as with most practices we have…...

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