Bryan Haywood

EPA RMP citations @ refinery (Flammables and HF Acid & $46K w/ $168K SEP)

Respondent owns and operates a refinery which produces, processes, handles, or stores, over the threshold amount, hydrogen, methane, ethane, ethylene, propane, propylene, butane, iso-butane, pentane, pentene, and iso-pentane. All are listed at 40 C.F.R. § 68.130 as regulated substances based on their flammability. At the Facility, the Respondent also produces, processes, handles, or stores, over

Proposes Over $1.8 Million in Fines Against a Corn Milling Facility After Fatal Grain Dust Explosion

OSHA has proposed $1,837,861 in fines against a corn milling facility following a May 31, 2017, explosion that killed five workers and injured 12 others, including a 21-year-old employee who suffered a double leg amputation after being crushed by a railcar. OSHA found that the explosion likely resulted from failures to correct the leakage and

Using CAMEO Tools for RMP and EPCRA Off-Site Consequence Analyses

This week NOAA’s Office of Response and Restoration posted an AWESOME RESOURCE for those of you responsible for your RMP’s Off-Site Consequence Analyzes (OCA) and EPCRA hazard analyses and who like to use CAMEO software suite when doing these off-site consequence analyses.   Part 1: Worst-Case Analysis (RMP) Part 2: Alternative Analysis (RMP) Part 3: ALOHA and Green Book

Evaluation of Fire and Rescue Services (OSHA 2017)

There has been a lot of discussions these past several years about having an “in-house emergency response team” vs. relying on “external response services” (e.g. local FD or contracted services on a case-by-case basis).  There is NO one right or wrong answer and each facility and its hazards and needs are all quite different.  This week

DOJ Consent Decree on RMP General Duty Clause @ fish processing and canning facility (Ammonia, Chlorine, and Butane)

This is from a recently posted Consent Decree for a fish processing facility.  From all I have seen this facility did NOT have RMP Covered processes using Anhydrous Ammonia, Chlorine or Butane and all of these actions stem from a General Duty Clause agreement, which is by far the most significant GDC agreement I can remember. 

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