Bryan Haywood

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

/ Free, 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 […]

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

/ Chemical Process Safety (PSM/RMP), Free /

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

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

/ Free, 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

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

/ Chemical Process Safety (PSM/RMP), Free /

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

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

/ Free, 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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