Bryan Haywood

OSHRC gets it wrong on 1910.1469(k) Rescue Plans

This case involved an industrial laundry company which uses continuous batch washers (CBW) which were correctly defined as a Permit-Required Confined Space (PRCS). During an OSHA inspection, the Compliance Officer (CO) took issue with the facility’s rescue plan from a CBW. After reading this case, I too took issue with their rescue plan; however, since…...

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OSHRC confirms that EXPIRED “calibration gas” for calibrating atmospheric testing equipment is a violation

This OSHRC case involved laundry company who uses industrial sized washing machines which are correctly classified as a Permit-Required Confined Space (PRCS).  OSHA inspected the facility, and the CSHO discovered that the calibration gas used to calibrate the direct reading meter that would be used for testing the atmosphere inside the continuous batch washers (CBW) has expired 18…...

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Did the OSHRC just say that blanking/blinding, disconnect/misalignment, or a DB&B is not required for PRCS isolation?

I often review the OSHRC decisions to learn better the “legal” side of OSHA compliance and most of the time I find that the Review Commission is pretty much a straight shooter when it comes to applying OSHA standards. But there are times when I close my computer as if I just saw a ghost…...

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OSHA’s 2017 Top 10

At this year’s NSC Congress OSHA announced their 2017 Top 10 Violations.  They have not updated their Data Page yet, but here are their preliminary…… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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EPA RMP citations @ ammonia manufacturer (NH3, 11,000 pound release & $25K w/ $200K SEP)

Respondent is primarily engaged in the production of anhydrous ammonia, urea fertilizer, and urea ammonium nitrate, which includes two ammonia units (A1 and A2), a urea production unit, a UAN unit, and various ancillary units, including a carbon dioxide pipeline compressor station and a hydrogen recovery unit. Respondent produces, processes, stores, or handles more than…...

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It took two (2) years, but HFO-1234yf is now an NFPA Flammable “4”

Back in early 2015, I began working with some clients who were questioning their having to enter into the Process Safety arena because of a new refrigerant that was going into automobiles.  Early in our discussions I was appalled that this flammable refrigerant had been “marketed and sold” with the description of being a “mildly flammable”…...

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2017 Video of the Week #41 (PRCS Accident – “Precious Time – The Cody McNolty story”)

On October 4,2001 Cody McNolty was working as a welder’s assistant in northern British Columbia. He was helping his father refit a log barge.  Four workers were rendered unconscious from a lack of oxygen. Dan McNolty (the father) died. Precious Time documents Cody’s story, a story of confined space rescue that goes tragically wrong.  Precious Time was created…...

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Flaring off NH3 and a few things to consider

This week social media once again provided us an eye-opening video… flaring off an MC331 Tanker of anhydrous ammonia (NH3).  In my days, I have flared off both tanker trucks and railcars, and even worked with flaring systems on refrigerated atmospheric bulk storage tanks of NH3 at large NH3 terminals and NH3 manufacturing plants.  The…...

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