Bryan Haywood

Failure of the Entry Supervisor to “verify rescue services are available” leads to an OSHA Willful Citation of $126,749 (Railcar & $204K)

/ Permit Required Confined Spaces /

I have written repeatedly about Confined Space rescue requirements and the problems with using off-site rescue teams, specifically referencing the requirement of 1910.146(j)(4)…  Duties of entry supervisors. The employer shall ensure that each entry supervisor: … 1910.146(j)(4) Verifies that rescue services are available and that the means for summoning them are operable; Now it seems that…...

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OSHA issues PSM Citations @ Food Plant (NH3 & $114K)

/ PSM and RMP Citations/Analysis /

One of OSHA “significant cases” in the month of August was a PSM case at a Frozen Specialty Food Manufacturing facility in KS.  Here is a breakdown of the citations:   NOTE: this case is PENDING ABATEMENT OF VIOLATIONS, PENDING PENALTY PAYMENT… Membership Required You must be a member to access this content.View Membership LevelsAlready a member?...

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NFPA 51B, NFPA 241, and your Fire Watch requirements

/ Chemical Process Safety (PSM/RMP) /

One of the debates we routinely have with fellow process safety professionals is the adoption of NFPA 51B vs. meeting 1910.252(a) requirements for their Hot Work safe work practice. I am a huge fan of NFPA 51B, as it is much more up-to-date than OSHA’s 1910.252; which by the way was based off of the…...

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$2.7 Million in Damages from Faulty Sight Glass Valves (BSEE Bulletin)

/ Chemical Process Safety (PSM/RMP) /

Check-valves are utilized in all sorts of applications, including safety applications – most notably in process safety and hazardous materials safety.  In some state fire codes, these valves may even be required in certain lines, and in some process safety RAGEGEPs, they are required.  Although this incident occurred in an off-shore rig, the sight-glass involved…...

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What is the state of OH proposing in their REVISED Fire Code

/ Hazardous Materials /

The state of Ohio is in the processing of upgrading the state’s fire code using the 2015 International Fire Code as its basis.  This is a summary of the chapters most often used in facilities that handle hazardous chemicals…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log...

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OSHA clarifies recording injuries/illnesses when supervision is shared by a prime contractor and subcontractor at a construction site

/ OSHA Compliance /

This 2017 letter of interpretation clarifies the requirements at Section 1904.31, Covered Employees. Specifically, OSHA clarifies who is responsible for recording injuries and illnesses of workers when a prime contractor and subcontractor share supervision at a construction site…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in...

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Changing the configuration of a space may also require a different energy isolation plan

/ Permit Required Confined Spaces /

In many industries where the heating or cooling process comes into play, the process will probably have some type of heat exchanger or condenser. In large-volume processes, these units can be enormous; easily large enough to bodily enter and do assigned work. But many of these units may not get identified as a Permit-Required Confined…...

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OSHA’s new publication “Process Safety Management for Petroleum Refineries”

/ Chemical Process Safety (PSM/RMP) /

OSHA has just released a new PSM Booklet titled “Process Safety Management for Petroleum Refineries,” which contains “Lessons Learned” from their Petroleum Refinery Process Safety Management National Emphasis Program (NEP).  This publication is a MUST READ for any practicing process safety professional, regardless if your process(s) is a refinery or not!  The publication focuses on…...

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EPA RMP citations @ chemical manufacturer (Formaldehyde & $9K)

/ PSM and RMP Citations/Analysis /

On May 14, 2014, EPA conducted a compliance inspection of Respondent’s facility to determine its compliance with the Risk Management Program (“RMP”) regulations promulgated at 40 C.F.R. Part 68 under Section 112(r) of the Act. EPA found that Respondent had violated regulations implementing Section 112(r) of the Act by failing to comply with the regulations as…...

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This “man-sized” door does NOT eliminate “limited means of egress”

/ Permit Required Confined Spaces /

As the debate continues in the refrigeration industry regarding the classification of evaporative condensers, I had someone send me a picture from one of the main manufacturers of evaporative condensers showing me an example of an evaporative condenser that no longer has “limited means of egress.” Therefore it is no longer a Confined Space and…...

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