Bryan Haywood

“It’s just Ammonia” – yep it sure is! (1992 Senegal/SONACOS catastrophe)

In my travels around the world, I find that many still view Anhydrous Ammonia as a “chemical that changed the world.”  From the fertilizer industry I hear how Anhydrous Ammonia has saved billions from starvation as it works its magic as a fertilizer; from the refrigeration industry, I head how it is the lowest global warming…...

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FEMA releases the refreshed National Incident Management System (NIMS)

This year’s active hurricane and fire seasons highlight the importance of working together before, during, and after disasters of all types and sizes. The National Incident Management System (NIMS) provides a standard, nationwide approach to enable the whole community to work together to manage all threats and hazards.  FEMA has released the refreshed NIMS to…...

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Make sure your “coded welder” certification is NOT out of date (ASME B31.3 and 31.5)

Recently we came across a project where questions arose concerning the welders on the job. The Welding Procedure Specification (WPS) was well written and listed the welders who would be making the welds on the piping being installed. But when asked to see the welders “certification records,” those records were older than six (6) months…....

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What does it mean when someone mentions the “VR Stamp” when discussing relief valves?

There may come a day when one of our pressure relief valves will need some type of work done on it and when that day comes we need to ensure the contractor/shop doing the work holds an “VR Stamp” from The National Board of Boiler and Pressure Vessel Inspectors.  The “VR” stands for “valve repair” and…...

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What does it mean when someone mentions the “R Stamp” when discussing pressure vessels?

There may come a day when one of our pressure vessels will need some work done on it, and when that day comes, we need to ensure the contractor doing the work holds an “R Stamp” from The National Board of Boiler and Pressure Vessel Inspectors.  The “R” stands for “repair” and anyone who makes…...

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National Board’s NEW Part 4 Cross Reference Cheat Sheet

The National Board Inspection Code (NBIC) is issued every two years and this year’s edition (2017) is now organized into four (4) parts. It is developed to maintain the integrity of pressure-retaining items by providing rules for installation (Part 1), and after the items have been placed into service, by providing standards for inspection (Part…...

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EPA RMP citations @ seafood processing plant (NH3 & $45K w/ $175K SEP)

Respondent owns a stationary source where anhydrous ammonia was present in a process above the 10,000 pound TQ from at least June 1, 2014. Therefore, Respondent was required to submit and have in place an RMP for the facility. Respondent submitted an RMP to EPA on April 9, 2015. Respondent has a Program 3 covered…...

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Playing “Who’s on first, What’s on second, I Don’t Know is on third” – with EPA’s R-134a refrigerant replacement (HFO-1234yf)

I may have been quick to “pat myself on my back” last week with my post titled “It took two (2) years, but HFO-1234yf is now a NFPA Flammable “4”, as this morning I learned from another client dealing with this refrigerant that their manufacturer also updated their SDS and guess what… that manufacturer went…...

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Is your car a traveling PSM covered process?

I have joked about this topic in other posts, as we have been battling the idea that our new refrigerant for vehicle air conditioners is a Category 1 Flammable Gas.  This conversion from R-134a has been a bumpy one, but in jest, I share with you EPA’s “use conditions,” and for an agency that certainly…...

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Did you see the “tagout” in CSB’s latest Bulletin

The US Chemical Safety Board’s (CSB) most recent Safety Bulletin: Key Lessons from the ExxonMobil Baton Rouge Refinery Isobutane Release and Fire was once again a great piece of work by the agency.  But as with most incidents, other underlying issues may have contributed (or not) to the incident.  In this bulletin, I could not help but notice…...

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Did the OSHRC just say that 1910.147 Appendix A without any revisions is an acceptable “machine specific” LOTO procedure?

The OSHRC sided with the company that used Appendix A from 1910.147 as their machine-specific LOTO procedure.  They did so without any revisions to the content of the Appendix, and the OSHRC found this as an acceptable machine-specific LOTO procedure!   … Membership Required You must be a member to access this content.View Membership LevelsAlready a...

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