Bryan Haywood

OSHA issues REPEAT LOTO & Guarding Citations ($503,380)

A manufacturer of rigid metal, plastic, and hybrid containers faces $503,380 in proposed penalties after OSHA inspectors responded to four (4) separate reports of workers suffering injuries at the facility. As a result of its investigations, OSHA cited the business for five (5) repeated and five (5) serious safety violations of machine safety procedures and placed…...

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“UPWARD” actually means UP, which is the opposite of down in RV Discharge Design

Relief System Design is not actually rocket science, so when our Recognized and Generally Accepted Good Engineering Practice (RAGAGEP) tells us that our relief valve discharge is to be in the “Upward” direction, this is not meant to be a “trick question”. But it does seem to stump a lot of engineers, case in point……...

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2017 Video of the Week #39 (PRCS Entry into tanker – so many things WRONG!)

You may be thinking this video was shot in 1950’s, but nope it is 2015!  If you ever wondered why we still have PRCS accidents in transportation containers, this may be a small indicator of why!  Make sure you have your volume up so you can hear their conversation – UNREAL (ESPECIALLY at the 15:15…...

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LOTO in 2017 has got to be better!

I spent this week surrounded by safety pros who wanted to learn the finer details of safety; one day was dedicated to LOTO.  I always get some questions about spending a day on LOTO… “what the heck are we going to talk about LOTO for 8 hours?”.  I think that if you were to poll…...

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EPA RMP citations @ cold storage (NH3 & $23K)

Respondent operates a food distribution plant with 33,400 pounds of ammonia for cold food storage purposes and is a RMProgram level 3 covered ammonia refrigeration process.  On February 11, 2016, the EPA conducted an onsite inspection of the RMProgram related records and equipment for the purpose of assessing the Respondent’s compliance with the RMProgram requirements,…...

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Can we have more than the PSM or RMP thresholds on site and not be covered under PSM or RMP?

The short answer is ABSOLUTELY WE CAN, but we need to be very careful about how we manage our hazardous materials. The purpose of this article is to clear the air about EPA’s use of our own Tier II reports against our facility… they can be an “indicator” of PSM/RMP covered processes but they are NOT…...

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2017 Video of the Week #38 (that barricade tape was there for a reason)

In my world, we always had a written barricading safe work practice.  This SWP covered everything from using “jersey barriers” to our bollards design and included the use of barricade tape:  YELLOW was for CAUTION and could be crossed as long as you had on the required PPE to be inside the barricaded area and…...

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EPA RMP citations @ CO2 plant (flammable mixture and NH3 & $?????

There appears to have been no monetary fine issued with this agreement; instead, it looks as if the facility has agreed to correct all the deficiencies by June 2018. Respondent uses, handles, and/or stores more than a threshold quantity of a flammable mixture and anhydrous ammonia, both regulated substances. The EPA conducted an inspection on…...

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OSHA issues LOTO citations regarding a ribbon blender fatality

At 11:57 a.m. on December 27, 2016, an employee, 27 years old, was performing a “salt flush” on line four 2,500 lb. double ribbon mixer. He/she dropped an 80 lb. bag of salt into the mixer.   A coworker walked down to close the mixer trap door, and the deceased employee entered the mixer to…...

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