Bryan Haywood

Contractor doing a PRCS Rescue Evaluation (1910.146(k) & 1926.1211)

PLEASE NOTE: This article may contain grammar errors, as this is my response to the more than 60 messages I received in the past seven days regarding last week’s article, When contractors enter a host’s PRCSs (1910.146(c)(8)(iii).   I have put this together tonight so as to not keep any of those who contacted me…...

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Anhydrous Ammonia unloaded to Propane Tanks (Wrong Chemical – Wrong Tank)

This is another Wrong Chemical – Wrong Tank incident in which Anhydrous Ammonia (NH3) was off-loaded to Propane Storage Tanks.   Two 30,000-gallon propane tanks, each at 70% capacity, were additionally filled to 85% with NH3. Similar plumbing on BOTH transport and storage tanks made the transfer possible, as both propane tanks shared common piping,…...

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FATAL Explosion and Fire at Acrylic Acid Production Facility (Polymerization Reaction in Intermediate Storage Tank)

At about 14:35 on 9/29/12, an explosion and fire occurred in an intermediate tank that temporarily stored bottom liquid from the glacial acrylic acid rectifying column. The fire then spread to the nearby equipment and buildings such as acrylic acid tanks, toluene tank and fire engines. Fatalities: 1 (firefighter) Severely injured: 5 (2 firefighters and…...

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Why Does OSHA Require Retention of Placards? (1910.1201)

At 3:40 a.m. on November 29, 1988, the Kansas City, MO Fire Department received an alarm indicating there was a fire at a highway construction project. The dispatcher directed Pumper 41 to respond to the truck fire. He added: “Pumper 41, use caution on your call. There’s information there may be explosives. It’s in a…...

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Where Did “Shelter-in-Place” Come From?

Last week was the anniversary of the anhydrous ammonia truck accident in Houston back in 1976 and out of that incident came what we call “Shelter-in-Place”.  About 11:08 a.m., on 11 May 1976, a Transport Company of Texas MC 331 tractor-semi trailer transporting 7,509 gallons of anhydrous ammonia struck and penetrated a bridge rail on…...

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BSEE Safety Bulletin No. 003 – Mud/Gas Separator Cleaning Results in PRCS Death

A fatal incident occurred when an Assistant Driller (AD) placed his head and an arm into a platform drilling rig’s vertical Mud/Gas Separator (MGS) through its inspection hatch, while performing the assigned, but non-routine task of removing built up and hardened material from inside the MGS.  A BSEE Panel investigation identified a number of established Safe Work Practices (SWPs)…...

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2017 Video of the Week #20 (Lack of guarding on winder – fatality)

SERIOUS WARNING!  This video is EXTREMELY GRAPHIC and viewer discretion is advised.  This video shows a worker being pulled into a “winder” and whipped around many times, killing him. FYI:  OSHA just issued (6/12017) citations for a fatality similar to this video.  CLICK HERE for the citations… Membership Required You must be a member to access...

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A MOC makes a great Halloween Costume…

I joke with my HAZMAT students that I am going to dress up as “IDLH” and scare everyone on Halloween and I joke with my PSM students that I am going to dress up as a MOC and scare everyone; it’s just meant to be a joke, but one day someone asked me… “What would…...

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EPA RMP citations @ chemical manufacturing plant (1,3-butadiene & $20K)

Respondent operates a chemical manufacturing plant that has one RMProgram level 3 covered chemical manufacturing process, which stores or otherwise uses 1,3-Butadiene in an amount exceeding its applicable threshold of 10,000 pounds. On November 9, 2015, the EPA conducted an onsite inspection of the RMProgram related records and equipment for the purpose of assessing the…...

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The State of MA revises their “Process Safety” standard “527 CMR 33.00: Hazardous Material Process or Processing”

The state of MA has modified it’s State HAZMAT code, formerly called 527 CMR 33.00: Hazardous Material Process or Processing. The process safety code, now found in the State Fire Cide, Chapter 60, Hazardous Materials, has added a “performance alternative”, as well as providing more specifics and updating definitions. Here is what’s new: NOTE: Still…...

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Do the actions taken under PSM duties/SOPs exempt the facility from the scope of HAZWOPER?

OSHA has two (2) significant LOIs, both aligning, and their HAZWOPER CPL that do a really good job of explaining how one crosses over from PSM SOP actions to actions that would fall under the definition of an “emergency response”, thus moving compliance from 1910.119 to 1910.120. I have presented both of these LOIs and…...

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