Bryan Haywood

EPA EPCRA citations @ paper mill for failing to report 4 Cl2 releases (Cl2 & $322K)

Respondent was the owner or operator of a pulp and paperboard manufacturing facility. At all times relevant to this Consent Agreement, Respondent was in charge of the Facility. At all times relevant to this Consent Agreement, Respondent produced, used, or stored chlorine at the Facility. Chlorine is a “hazardous substance” listed in 40 C.F.R. Part…...

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EPA RMP citations @ chicken processing plant (NH3 & $10K w/ $37K SEP)

This case reflects a common issue in ammonia refrigeration: Lack of or Poor Lockout/Tagout Practices. This 1,600-pound release was caused by an existing ammonia compressor that was started up on an ammonia line that was meant to be “TAGGED OUT” of service (however, the tag had fallen off) while in the process of tying the…...

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Non-Compliant Exit Signs

A few weeks back, I mentioned that some “safety vendors” sell non-compliant EXIT signs. I received several inquiries about what I was talking about, as if “surely it’s not so.”  I am not going to call out these irresponsible safety vendors, but there are many!  I have even seen EXIT signs that the entire sticker/sign…...

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OSHA’s HIPP Proposed Standard (With my commentary and questions)

OSHA has released a proposed Heat Illness Protection Plan (HIPP) to protect millions of workers from the significant health risks of extreme heat. If finalized, the proposed rule would help protect approximately 36 million workers in indoor and outdoor work settings and substantially reduce heat injuries, illnesses, and deaths in the workplace. The proposed rule…...

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EPA RMP and EPCRA citations @ water treatment plant (Cl2 & $47K w/ $250K SEPs)

Respondent owns and operates a wastewater treatment plant that uses chlorine, stored as liquified gas under pressure, to disinfect wastewater. In its October 2020 risk management plan, the plant indicated that it stored up to 12,000 pounds of chlorine on-site in one-ton cylinders. On November 3, 2022, EPA performed an inspection of the plant to…...

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Employee cleaning tank dies after chemically (CH2Cl2) asphyxiated

On December 4, 2023, at 11:37 a.m., an employee was working as a contractor performing repairs at a bulk petroleum storage facility. The employee was attempting to perform repair work inside a tank that had previously contained oil. The employee was using methylene chloride to degrease the floor inside the tank…. Membership Required You must...

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Employee dies from CO exposure while cleaning bulk liquid tank

On December 23, 2023, at 12:07 p.m., an employee working as an equipment washer for a contract tank service was cleaning a bulk liquid waste tank that had contained acetic acid. The employee was found unresponsive inside the tanker. The employee was transported to the emergency room and was pronounced dead eleven minutes after arrival…....

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Slings Standard (29 CFR 1910.184) paperwork requirements

The Slings Standard (29 CFR 1910.184) specifies several paperwork requirements, depending on the type of sling (paragraph (e) of the Standard covers alloy steel chain slings; paragraph (f) covers wire rope slings; paragraph (g) covers metal mesh slings; paragraph (h) covers natural and synthetic fiber-rope slings; and paragraph (i) covers synthetic web slings)…. Membership Required...

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Safety Thought of the Week & Defending H.W. Heinrich – He was a NOT proponent of SIF back in 1929.

All this talk about “Sh_t That Can Kill You” (STCKY) and focusing on those Low-Frequency, High-Severity risks is just one of the current safety fads. I like SIF, and if you really think about it, SIF and Process Safety are very much aligned. But I have never understood why it needed to be its own…...

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Safety Thought of the Week & Defending H.W. Heinrich – He was a NOT proponent of SIF back in 1929. Read More »

If you had to choose which two (2) SMS elements to implement first, which would you choose?

In my experience, I have come to understand two (2) SMS/PSMS elements need to be first in line for development and implementation, as these two (2) elements are critical in the early days of developing and implementing a formal/structured SMS/PSMS. What would your two (2) elements be? My two are:… Membership Required You must be...

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Li Battery Storage ideas (compartmentalizing our risks)

Throughout my career, I have been called “crazy,” “certifiable,” “unreasonable,” etc. I have worn those insults as a badge of honor, as in my professional opinion, there is nothing too crazy to protect the men and women doing the dirty and dangerous work! So buckle up, as this thought process may push you over the…...

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Accidents, their cost, and traffic jams caused by accidents

Many safety pros struggle to get management to understand the “indirect costs” of accidents. This is a real cost to the business, but those outside our profession are so far outside that they struggle to grasp the “indirect cost.”  Heck, many fail to grasp the “direct costs” since they do not come out of their…...

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