Bryan Haywood

PSM and RMP… Design codes and standards employed

Both OSHA’s and EPA’s process safety standards have a requirement called “Design codes and standards employed”, but why do the standards require this and what should it look like in our Process Safety Information management system?  In a review of our past audits, we almost always find gaps in the facility’s list of Design codes and…...

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Fatality Alert – Overpressure of an Explosion-Proof Enclosure

An analyzer engineer was fatality injured when the engineer removed the cover on an explosion-proof enclosure as part of a routine task. The threaded cover weighing ~12 lbs. and measuring 14 inches in diameter was forcefully propelled from the enclosure as the engineer unscrewed it inflicting a fatal head injury. The force was caused by…...

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EPA delays the effective date of the RMP Amendments for an additional 20 months

The Environmental Protection Agency (EPA) is delaying the effective date of the Risk Management Program Amendments for an additional 20 months, to allow EPA to conduct a reconsideration proceeding and to consider other issues that may benefit from additional comment. The new effective date of the rule is FEBRUARY 19, 2019. The Risk Management Program…...

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Interesting response to leaking NH3 Tank Truck (Outside of USA)

This video is interesting on many levels and since it occurred outside of the USA I am not sure about any regulatory issues in the home country, but if this were in the USA we can see a number of issues.  However, this video shows us the conditions under which we might respond to an ammonia…...

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Washington Board of Industrial Insurance Appeals VACATES ALL of WA-OSHA PSM citations related to 2010 Refinery Explosion that killed 7

The Department of Labor and Industries cited a refinery for forty-five alleged violations of various Washington Administrative Code sections assessing a penalty of $2,393,000 as a result of an explosion and fire that occurred at the refinery on the early morning of April 2, 2010 that resulted in seven fatalities. The refiner contends that it…...

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2017 Video of the Week #24 (Distracted Walking or OPEN PIT the issue?)

This week, the video below has gone viral and many have blamed the elderly lady of not paying attention to where she’s going as the cause of this accident; but what do you say is the ROOT CAUSE of this accident?  What other issues can we identify in this accident?  Let’s assume the work would…...

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OSHA’s CHEM NEP Update by the Numbers (June 7, 2017)

This week the USDOL-OSHA, Directorate of Enforcement Programs, Office of Chemical Process Safety and Enforcement Initiatives team (Jeff Wanko, Jim Lay and Mike Marshall) presented an update on OSHA’s PSM Activities.  This is the first such kind of update in over a year so it has some interesting DATA and updates to OSHA CHEM NEP approach. I have…...

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PHMSA’s New Cylinder “Special Permit” authorizes an extension of the 15-year service life of certain carbon fiber reinforced aluminum-lined cylinders (DOT-CFFC)

The U.S. Department of Transportation’s (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) has announced it has issued a special permit to authorize the extension of the 15-year service life of certain carbon fiber reinforced aluminum-lined cylinders (DOT-CFFC) that are used in self-contained breathing apparatuses by fire departments and first responders…. Membership Required You must...

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PHMSA Adjusts Maximum and Minimum Civil Penalties for Inflation

The Pipeline and Hazardous Materials Safety Administration (PHMSA) issued a Final Rule to revise its regulations and increase the maximum civil penalty amount for violations of the Federal hazardous materials safety law. Under the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015, which further amended the Federal Civil Penalties, Inflation Adjustment Act of…...

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Timing of HBV shots is UPHELD by OSHRC as critical to BBP Control Plan effectiveness

If you have a First-Aid team that “renders aid” as part of their job duties (even though their participation on the team is voluntary – but rendering care once on the team is NOT) this is a case you should understand.  The business was cited for NOT having the employees vaccinated at the time-frames stated…...

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Why our Pressure Safety Valves must meet the phase they will see in an overpressure event

Is there such a thing as a “dual phase” pressure safety valve (PSV)? Not that I have ever encountered; yet that does not stop some from trying to “educate me” on their dual-phase PSVs. So why does this topic matter? Our PSV’s are our LAST LINE of defense in an overpressure event, and if they…...

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